Ochoa v. City of San Jose

District Court, N.D. California·Decided May 23, 2022·No. 5:21-cv-02456·Unknown

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 SAN JOSE DIVISION 6 7 YURIDIA OCHOA, Case No. 21-cv-02456-BLF

8 Plaintiff, ORDER GRANTING PLAINTIFF 9 v. YURIDIA OCHOA’S MOTION TO STRIKE AFFIRMATIVE DEFENSES 10 CITY OF SAN JOSE, et al., FROM DEFENDANTS CITY OF SAN JOSE AND ERIC MOSUNIC’S FIRST 11 Defendants. AMENDED ANSWERS TO FIRST AMENDED COMPLAINT WITH 12 LEAVE TO AMEND 13 [Re: ECF No. 55]

14 15 Before the Court is Plaintiff Yuridia Ochoa’s motion to strike affirmative defenses in the 16 First Amended Answers of Defendants City of San Jose (the “City”) and San Jose Police Department 17 (“SJPD”) Officer Eric Mosunic (“Officer Mosunic”) in this civil rights case related to SJPD officer 18 conduct related to Plaintiff’s arrest. Plaintiff brings federal claims under section 1983 and various 19 state law claims, including unreasonable post-arrest medical care, intentional infliction of emotional 20 distress, and negligence claims. See First Amended Complaint, ECF No. 45. 21 The City and Officer Mosunic filed separate answers, each raising eight affirmative 22 defenses. See City’s First Amended Answer (“City Answer”), ECF No. 52; Officer Mosunic’s First 23 Amended Answer (“Mosunic Answer”), ECF No. 53. The sixth and seventh affirmative defenses 24 from the City’s answer and the seventh and eighth affirmative defenses from Officer Mosunic’s 25 answer (collectively, the “Challenged Defenses”) allege the City and Officer Mosunic are entitled 26 to immunity under a list of California Government Code and California Penal Code provisions. See 27 City Answer, ECF No. 52 at 25–26; Mosunic Answer, ECF No. 53 at 25–26. 1 Defenses are inadequately pled, since they merely list allegedly applicable statutory provisions 2 without factual support or explanation. See Motion, ECF No. 55; Reply, ECF No. 57. In response, 3 Defendants argue that the pleading standard for affirmative defenses is a low bar and the Challenged 4 Defenses are clear in light of the First Amended Complaint. See Opposition, ECF No. 52. 5 Based on the below reasoning, the Court GRANTS Plaintiff’s motion. The Court STRIKES 6 the Challenged Defenses WITH LEAVE TO AMEND. To the extent the Challenged Defenses are 7 alleged to apply to Plaintiff’s federal claims, the Challenged Defenses are stricken WITHOUT 8 LEAVE TO AMEND. 9 I. LEGAL STANDARD 10 Federal Rule of Civil Procedure 12(f) permits a court to “strike from a pleading an 11 insufficient defense or any redundant, immaterial, impertinent, or scandalous matter.” The function 12 of a motion made under this rule is “to avoid the expenditure of time and money that must arise 13 from litigating spurious issues by dispensing with those issues prior to trial.” Whittlestone, Inc. v. 14 Handi-Craft Co., 618 F.3d 970, 973 (9th Cir. 2010) (quotation marks and citation omitted). 15 II. DISCUSSION 16 The Challenged Defenses allege that the City and Officer Mosunic are entitled to immunity 17 under provisions of the California Government Code and the California Penal Code. The City’s 18 sixth affirmative defense alleges it is entitled to immunity under California Government Code 19 sections 815.2(b), 820.2, 820.4, 820.8, 821, 821.6, and 822.2. See City Answer, ECF No. 52 at 25. 20 The City’s seventh affirmative defense alleges it is entitled to immunity under California Penal Code 21 sections 834(a), 835, 835(a), 836, and 836.5. See id. at 25–26. Officer Mosunic’s seventh 22 affirmative defense alleges he is entitled to immunity under California Government Code sections 23 820.2, 820.4, 820.8, 821.6, and 822.2. See Mosunic Answer, ECF No. 53 at 25–26. Officer 24 Mosunic’s eighth affirmative defense alleges he is entitled to immunity under California Penal Code 25 sections 834(a), 835, 835(a), 836, and 836.5. See id. at 26. 26 Plaintiff moves to strike the Challenged Defenses as inadequately pled. Plaintiff argues that 27 (1) the Challenged Defenses should be stricken to the extent they allege state law immunities apply 1 factual allegations; and (3) some of the challenged California Government Code defenses should be 2 stricken because they are inapplicable or redundant regardless of the sufficiency of Defendants’ 3 pleadings. See Motion, ECF No. 55; Reply, ECF No. 57. Defendants oppose. See Opposition, 4 ECF No. 52. The Court considers each issue in turn. 5 A. Applicability of State Statutory Immunity Provisions to Federal Claims 6 Plaintiff argues that the Challenged Defenses, which are based on state statutory immunity 7 provisions, should be stricken to the extent they are alleged to apply to Plaintiff’s federal claims. 8 See Motion, ECF No. 55 at 5, 7. The Challenged Defenses include the following language: “as 9 applicable to all causes of action asserted in Plaintiff’s First Amended Complaint.” See City 10 Answer, ECF No. 52 at 25–26; Mosunic Answer, ECF No. 53 at 25–26. Defendants agree that the 11 state statutory immunity provisions do not apply to Plaintiff’s federal claims. See Opposition, 12 ECF No. 56 at 8–9. Accordingly, the Court STRIKES the Challenged Defenses to the extent they 13 are alleged to apply to Plaintiff’s federal claims. 14 B. Sufficiency of Pleading 15 Plaintiff argues that the City and Officer Mosunic have failed to adequately plead the 16 Challenged Defenses because they merely list statutory provisions and provide no supporting factual 17 allegations. See Motion, ECF No. 5–6, 7–8; Reply, ECF No. 57 at 4–6. Plaintiff argues that the 18 City and Officer Mosunic’s pleading fails to meet the heightened “plausibility” standard laid out in 19 Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal, 556 U.S. 662 (2009). 20 See Motion, ECF No. 55 at 3–4. Further, Plaintiff argues that a showing of prejudice is not 21 necessary to strike a defense, and even if it were, the burden of “discover[ing] the secrets of a 22 contextually incomprehensible affirmative defense” is sufficient to show prejudice here. See 23 Motion, ECF No. 55 at 9 (citation omitted). In response, Defendants argue that only a “fair notice” 24 standard applies to pleading affirmative defenses. See Opposition, ECF No. 56 at 2–3. Further, 25 Defendants argue that pleading affirmative defenses by pointing to specific statutory provisions is 26 adequate, particularly “in the context of Plaintiff’s allegations.” See Opposition, ECF No. 56 at 2–3, 27 6–7. Additionally, Defendants argue that Plaintiff fails to articulate what he does not understand 1 The Court agrees with Plaintiff. Courts generally apply the Twombly/Iqbal plausibility 2 standard to pleading affirmative defenses, and the Court sees no reason that standard should not 3 apply here. See, e.g., Bottero v. Hoya Corp., No. 14–cv–02528–BLF, 4 2015 U.S. Dist. LEXIS 47740, at *4 (N.D. Cal. Apr. 10, 2015). In any case, the Court does not see 5 how the Challenged Defenses provide either fair notice or a plausible basis for the alleged 6 immunities, since the Challenged Defenses are supported by no factual allegations in the City or 7 Officer Mosunic’s answer. Courts regularly strike similarly pled affirmative defenses. See 8 Lumasense Techs., Inc. v. Advanced Eng’g Servs., LLC, No. 20–cv–07905–WHO, 9 2021 WL 2953237 (N.D. Cal. July 14, 2021); Neylon v. Cty. of Inyo, No. 1:16–CV–0712 AWI JLT, 10 2017 WL 3670925, at *10 (E.D. Cal. Aug. 25, 2017) (striking affirmative defense that “requires 11 [plaintiff] to guess . . . at what conduct is entitled to immunity, and how the immunity might apply 12 or to which claims the immunity might apply”). Defendants’ cases are distinguishable. See 13 Adtrader, Inc. v. Google LLC, No.

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