Mitchell v. County of Contra Costa

CourtDistrict Court, N.D. California
DecidedFebruary 22, 2022
Docket4:21-cv-05014
StatusUnknown

This text of Mitchell v. County of Contra Costa (Mitchell v. County of Contra Costa) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mitchell v. County of Contra Costa, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 KESHAWN FULTON MITCHELL, Case No. 21-cv-05014-DMR

8 Plaintiff, ORDER ON MOTION TO DISMISS 9 v. Re: Dkt. No. 15 10 COUNTY OF CONTRA COSTA, et al., 11 Defendants.

12 Plaintiff Keshawn Fulton Mitchell filed a complaint against Defendants County of Contra 13 Costa (“Contra Costa”) and law enforcement officers Thomas Brook and Kyle Emley alleging 14 claims arising out of his February 2020 arrest. Defendants now move pursuant to Federal Rule of 15 Civil Procedure 12(b)(6) to dismiss Mitchell’s claims for supervisory liability and municipal 16 liability under Monell v. Department of Social Services of City of New York, 436 U.S. 658 (1978). 17 [Docket No. 15.] This matter is suitable for disposition without oral argument. Civ. L.R. 7-1(b). 18 For the following reasons, Defendants’ motion is granted. 19 I. BACKGROUND 20 The complaint contains the following allegations, all of which are taken as true for 21 purposes of this motion.1 Brook and Emley are officers with the Contra Costa County Sheriff’s 22 Office (“CCCSO”). Compl. ¶ 5. On February 27, 2020, Mitchell surrendered to Brook and Emley 23 after they ordered him to do so. He alleges that while he was “face-down on the ground with arms 24 out and away from his body in full surrender fashion,” the officers subjected him to excessive 25 force, including baton strikes and “stomping” to the back of his head. Id. at ¶ 12. Mitchell further 26 1 When reviewing a motion to dismiss for failure to state a claim, the court must “accept as true all 27 of the factual allegations contained in the complaint.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) 1 alleges that he was arrested and charged with violating California Penal Code section 148(a)(1)2 2 based on “deliberately fabricated facts.” Id. at ¶ 13. According to Mitchell, the officers fabricated 3 claims that Mitchell ignored their commands “to stop running and get on the ground” after they 4 identified themselves, resulting in a foot chase that ended when Mitchell tried and failed to jump 5 over a fence. Id. at ¶ 12. Mitchell denies that he ignored the officers’ commands, engaged in a 6 foot chase, or attempted to jump over the fence. Id. He also alleges that he “did not, at any time, 7 physically resist, threaten, batter, or assault any Defendant,” fail to obey any order, or “delay, 8 obstruct, or interfere” with the officers’ duties. Id. at ¶ 14. Mitchell’s prosecution “was subject to 9 a Misdemeanor Pre-Trial Diversion Order . . . without a plea.” Id. at ¶ 13. 10 Mitchell alleges the following claims for relief: 1) a 42 U.S.C. § 1983 claim for violations 11 of the Fourth Amendment based on excessive force, unlawful arrest, and fabrication of material 12 facts against Brook and Emley and Doe Defendants 1 to 100; 2) a 42 U.S.C. § 1983 claim against 13 Contra Costa and Doe Defendants 101 to 200 for a) municipal liability under Monell and 2) 14 supervisory liability. 15 Defendants now move to dismiss the Monell claim and the supervisory liability claims. 16 II. LEGAL STANDARD 17 A motion to dismiss under Rule 12(b)(6) tests the legal sufficiency of the claims alleged in 18 the complaint. See Parks Sch. of Bus., Inc. v. Symington, 51 F.3d 1480, 1484 (9th Cir. 1995). 19 When reviewing a motion to dismiss for failure to state a claim, the court must “accept as true all 20 of the factual allegations contained in the complaint,” Erickson, 551 U.S. at 94 (citation omitted), 21 and may dismiss a claim “only where there is no cognizable legal theory” or there is an absence of 22 2 The relevant provision of California Penal Code section 148 states: 23

Every person who willfully resists, delays, or obstructs any public 24 officer, peace officer, or an emergency medical technician . . . in the discharge or attempt to discharge any duty of his or her office or 25 employment, when no other punishment is prescribed, shall be punished by a fine not exceeding one thousand dollars ($1,000), or by 26 imprisonment in a county jail not to exceed one year, or by both that fine and imprisonment. 27 1 “sufficient factual matter to state a facially plausible claim to relief.” Shroyer v. New Cingular 2 Wireless Servs., Inc., 622 F.3d 1035, 1041 (9th Cir. 2010) (citing Ashcroft v. Iqbal, 556 U.S. 662, 3 677-78 (2009); Navarro v. Block, 250 F.3d 729, 732 (9th Cir. 2001)) (quotation marks omitted). 4 A claim has facial plausibility when a plaintiff “pleads factual content that allows the court to 5 draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 6 U.S. at 678 (citation omitted). In other words, the facts alleged must demonstrate “more than 7 labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” 8 Bell Atl. Corp. v. Twombly, 550 U.S. 554, 555 (2007) (citing Papasan v. Allain, 478 U.S. 265, 286 9 (1986)); see Lee v. City of L.A., 250 F.3d 668, 679 (9th Cir. 2001), overruled on other grounds by 10 Galbraith v. Cty. of Santa Clara, 307 F.3d 1119 (9th Cir. 2002). 11 As a general rule, a court may not consider “any material beyond the pleadings” when 12 ruling on a Rule 12(b)(6) motion. Lee, 250 F.3d at 688 (citation and quotation marks omitted). 13 However, “a court may take judicial notice of ‘matters of public record,’” id. at 689 (citing Mack 14 v. S. Bay Beer Distrib., 798 F.2d 1279, 1282 (9th Cir. 1986)), and may also consider “documents 15 whose contents are alleged in a complaint and whose authenticity no party questions, but which 16 are not physically attached to the pleading,” without converting a motion to dismiss under Rule 17 12(b)(6) into a motion for summary judgment. Branch v. Tunnell, 14 F.3d 449, 454 (9th Cir. 18 1994), overruled on other grounds by Galbraith, 307 F.3d at 1125-26. The court need not accept 19 as true allegations that contradict facts which may be judicially noticed. See Mullis v. U.S. Bankr. 20 Court, 828 F.2d 1385, 1388 (9th Cir. 1987). 21 III. DISCUSSION 22 A. Monell Claim 23 1. Legal Standards for Monell Liability 24 A municipality may face section 1983 liability if it “‘subjects’ a person to a deprivation of 25 rights or ‘causes’ a person ‘to be subjected’ to such deprivation.” Connick v. Thompson, 563 U.S. 26 51, 60 (2011) (quoting Monell, 436 U.S. at 692). However, the municipality may be held liable 27 “only for ‘[its] own illegal acts.’” Id. (quoting Pembaur v. Cincinnati, 475 U.S. 469, 479 (1986)). 1 municipal liability, plaintiffs “must prove that ‘action pursuant to official municipal policy’ caused 2 their injury.” Id. (quoting Monell, 436 U.S. at 691).

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Mitchell v. County of Contra Costa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-county-of-contra-costa-cand-2022.