Moffitt v. County of San Diego

CourtDistrict Court, S.D. California
DecidedFebruary 10, 2025
Docket3:24-cv-01445
StatusUnknown

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

Bluebook
Moffitt v. County of San Diego, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JOHN MOFFITT, Case No. 24-cv-1445-MMA-DDL

12 Plaintiff, ORDER: 13 v. (1) GRANTING IN PART AND 14 COUNTY OF SAN DIEGO, et al., DENYING IN PART CITY OF SAN 15 Defendants. DIEGO’S MOTION TO DISMISS; AND 16

17 (2) GRANTING IN PART AND DENYING IN PART COUNTY OF 18 SAN DIEGO’S MOTION TO 19 DISMISS

20 [Doc. Nos. 12, 13] 21 22 On December 18, 2024, Defendants City of San Diego (including “San Diego 23 Police Department”) (“City Defendants”) Defendant County of San Diego, e/s/a San 24 Diego County Sheriff’s Department and San Diego County Jail (“County Defendants”) 25 (collectively, “Defendants”) filed respective motions to dismiss Plaintiff John Moffitt’s 26 (“Plaintiff”) second amended complaint. Doc. Nos. 12–13. Plaintiff filed responses in 27 opposition to each, to which Defendants replied in turn. Doc. Nos. 14–17. The Court 28 found these matters suitable for determination on the papers and without oral argument 1 pursuant to Federal Rule of Civil Procedure 78(b) and Civil Local Rule 7.1.d.1 and took 2 them under submission on January 17, 2025. Doc. No. 18. For the reasons below, the 3 Court GRANTS IN PART and DENIES IN PART County Defendants’ motion and 4 GRANTS IN PART and DENIES IN PART the City Defendants’ motion. 5 I. BACKGROUND1 6 On January 1, 2023, Plaintiff was sleeping in his residence when San Diego Police 7 Department officers entered his apartment. Doc. No. 11 (“SAC”) ¶¶ 16, 21. To gain 8 entry, police had “contacted a manager of the facility,” who provided them an electronic 9 key fob. Id. ¶ 45. The officers, however, did not “assess whether Plaintiff was present, 10 asleep, or awake.” Id. Without searching his apartment, police released a canine unit 11 inside. Id. ¶ 21. The canine bit Plaintiff, causing him serious bite wounds. Id. ¶ 22–23. 12 During the officers’ attempt to arrest him, Plaintiff “did not threaten the officers, did not 13 lunge at the officers, did not yell or do anything while in the apartment” to indicate that 14 he may be a threat. Id. ¶ 45. 15 After arresting Plaintiff, the officers transported him to San Diego County Jail. Id. 16 ¶ 24. Upon his arrival, Plaintiff exhibited open bite wounds to his arm. Id. ¶ 16. This 17 condition exposed him to infection. Id. While detained at the county jail, Plaintiff 18 “repeatedly asked for the custodial staff to advise the medical staff that he needed 19 emergency medical care. The custodial staff2 repeatedly denied said requests stating he 20 did not need that care.” Id. Eventually, however, Plaintiff was provided medical care, 21 though “the medical staff did not deem it necessary . . . to send him to the hospital for the 22 care he needed.” Id. Eventually his arm became infected, which led to sepsis. Id. ¶ 26. 23 Upon becoming septic, “he was finally transferred to an outside medical facility where he 24

25 26 1 Because this matter is before the Court on a motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), the Court must accept as true the allegations set forth in the Complaint and draw all 27 inferences in the light most favorable to the nonmovant. See Barker v. Riverside Cnty. Office of Educ., 584 F.3d 821, 824 (9th Cir. 2009). 28 1 was hospitalized for weeks.” Id. Plaintiff’s “arm was nearly amputated, requires further 2 medical attention, and he has suffered severe physical and emotional damage.” Id. ¶ 27. 3 Plaintiff initiated this action in state court on December 19, 2023, and Defendants 4 removed this action on August 14, 2024. Doc. No. 1. Defendants subsequently filed 5 motions to dismiss Plaintiff’s first amended complaint, which the Court granted on 6 November 13, 2024. Doc. Nos. 3–10. Plaintiff filed a second amended complaint on 7 December 4, 2024, alleging three causes of action: (1) Violation of Civil Rights (42 8 U.S.C. § 1983); (2) Negligence – Professional; and (3) Excessive Force. SAC ¶¶ 35–73. 9 II. LEGAL STANDARD 10 A Rule 12(b)(6) motion to dismiss tests a complaint’s sufficiency. Navarro v. 11 Block, 250 F.3d 729, 732 (9th Cir. 2001). “While a complaint attacked by a Rule 12 12(b)(6) motion to dismiss does not need detailed factual allegations, a plaintiff’s 13 obligation to provide the grounds of his entitlement to relief requires more than labels and 14 conclusions, and a formulaic recitation of the elements of a cause of action will not do. 15 Factual allegations must be enough to raise a right to relief above the speculative level.” 16 Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (internal quotations, brackets, and 17 citations omitted). Rule 12(b)(6) requires a complaint to “contain sufficient factual 18 matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft 19 v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 20 544, 570 (2007)). 21 Reviewing a motion to dismiss under Rule 12(b)(6), the court must assume the 22 truth of all factual allegations and must construe them in the light most favorable to the 23 nonmoving party. Cahill v. Liberty Mut. Ins. Co., 80 F.3d 336, 337–38 (9th Cir. 1996). 24 Legal conclusions need not be taken as true merely because they are cast in the form of 25 factual allegations. Roberts v. Corrothers, 812 F.2d 1173, 1177 (9th Cir. 1987); 26 W. Mining Council v. Watt, 643 F.2d 618, 624 (9th Cir. 1981). Similarly, “conclusory 27 allegations of law and unwarranted inferences are not sufficient to defeat a motion to 28 dismiss.” Pareto v. Fed. Deposit Ins. Corp., 139 F.3d 696, 699 (9th Cir. 1998). In 1 determining the propriety of a Rule 12(b)(6) dismissal, generally, a court may not look 2 beyond the complaint for additional facts. United States v. Ritchie, 342 F.3d 903, 908 3 (9th Cir. 2003); Parrino v. FHP, Inc., 146 F.3d 699, 705–06 (9th Cir. 1998). 4 When a motion to dismiss is granted, the court must decide whether to grant leave 5 to amend. The Ninth Circuit has a liberal policy favoring amendments, and thus leave to 6 amend should be freely granted. See, e.g., DeSoto v. Yellow Freight Sys., Inc., 957 F.2d 7 655, 658 (9th Cir. 1992). However, a court need not grant leave to amend when 8 permitting a plaintiff to amend would be an exercise in futility. See, e.g., Rutman Wine 9 Co. v. E. & J. Gallo Winery, 829 F.2d 729, 738 (9th Cir. 1987) (“Denial of leave to 10 amend is not an abuse of discretion where the pleadings before the court demonstrate that 11 further amendment would be futile.”). 12 III. DISCUSSION 13 Defendants move to dismiss each cause of action in Plaintiff’s second amended 14 complaint. Doc. Nos. 12–13. Plaintiff opposes dismissal. Doc. Nos. 14–15. In its prior 15 order granting Defendants’ respective motions to dismiss the first amended complaint, 16 Doc. Nos. 3–4, the Court dismissed Plaintiff’s claims, some with prejudice, and some 17 without. See generally Doc. No. 10.

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Moffitt v. County of San Diego, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moffitt-v-county-of-san-diego-casd-2025.