Ogden v. Ontario Oregon City Police Dept

CourtDistrict Court, D. Oregon
DecidedFebruary 12, 2021
Docket2:20-cv-02262
StatusUnknown

This text of Ogden v. Ontario Oregon City Police Dept (Ogden v. Ontario Oregon City Police Dept) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ogden v. Ontario Oregon City Police Dept, (D. Or. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON SHAWN C. OGDEN, Case No. 2:20-cv-02262-YY Plaintiff, ORDER TO DISMISS v. ONTARIO OREGON CITY POLICE DEPT; ROAD RUNNER TOWING; DALLAS BROCKETT; and STEVEN ROMERO, Defendants. IMMERGUT, J. Plaintiff, an adult in custody at the Malheur County Jail, brings this civil rights action pursuant to 42 U.S.C. § 1983. Pursuant to an Order entered this date, the Court granted plaintiff’s Application to Proceed In Forma Pauperis. However, for the reasons set forth below, the Court dismisses plaintiff’s Complaint. 1 - ORDER TO DISMISS BACKGROUND Plaintiff alleges that defendants violated his Fourteenth Amendment substantive due process rights, as well as his rights under 42 U.S.C. §§ 1985, 1986, and 12132, by towing his vehicle without providing a 72-hour notice. By way of remedy, plaintiff seeks money damages.

STANDARDS A district court must dismiss an action initiated by a prisoner seeking redress from a governmental entity or officer or employee, if the Court determines that the action (i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief. See 28 U.S.C. §§ 1915(e)(2) & 1915A(b). When a plaintiff is proceeding pro se, the court must construe the pleadings liberally and afford the plaintiff the benefit of any doubt. Erickson v. Pardus, 551 U.S. 89, 94 (2007). Moreover, before

dismissing a pro se civil rights complaint for failure to state a claim, the court supplies the plaintiff with a statement of the complaint’s deficiencies. Karim-Panahi v. Los Angeles Police Dept., 839 F.2d 621, 623-24 (9th Cir. 1988); Eldridge v. Block, 832 F.2d 1132, 1136 (9th Cir. 1987). A pro se litigant will be given leave to amend his or her complaint unless it is clear that the deficiencies of the complaint cannot be cured by amendment. Karim-Panahi, 839 F.2d at 623; Lopez v. Smith, 203 F.3d 1122, 1130-31 (9th Cir. 2000). DISCUSSION To state a claim under 42 U.S.C. § 1983, a complaint must allege that a defendant, while

acting under color of state law, caused a deprivation of the plaintiff’s federal rights. 42 U.S.C. § 1983; West v. Atkins, 487 U.S. 42, 48 (1988) (citations omitted); Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989) (citation omitted). A § 1983 plaintiff must establish both causation-in-fact and 2 - ORDER TO DISMISS proximate (i.e., legal) causation. See Harper v. City of Los Angeles, 533 F.3d 1010, 1026 (9th Cir. 2008). Allegations regarding Section 1983 causation “must be individualized and focus on the duties and responsibilities of each individual defendant whose acts or omissions are alleged to have caused a constitutional deprivation.” Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988) (citations omitted).

“Sweeping conclusory allegations [regarding causation] will not suffice[.]” Id. (citation omitted). To the extent plaintiff alleges the impoundment of his vehicle violated his substantive due process rights under the Fourteenth Amendment, the Complaint fails to state a claim upon which relief may be granted. The substantive protections of the due process clause bar certain governmental actions regardless of the fairness of the procedures that are used to implement them. Cty. of Sacramento v. Lewis, 523 U.S. 833, 840 (1998). Therefore, the substantive protections of the due process clause are intended to prevent government officials from abusing their power or

employing it as an instrument of oppression. Lewis, 523 U.S. at 846. The Supreme Court has held that “the substantive component of the Due Process Clause is violated by executive action only when it ‘can properly be characterized as arbitrary, or conscience shocking, in a constitutional sense.’” Id. at 847. “[O]nly the most egregious official conduct can be said to be arbitrary in a constitutional sense.” Brittain v. Hansen, 451 F.3d 982, 990 (9th Cir. 2006) (quoting Lewis, 523 U.S. at 846). “Substantive due process is ordinarily reserved for those rights that are ‘fundamental.’” Brittain, 451 F.3d at 990. “The protections of substantive due process have for the most part been accorded to matters relating to marriage, family, procreation, and the right to bodily integrity[;] and

the Supreme Court has been reluctant to expand the concept of substantive due process.” Albright v. Oliver, 510 U.S. 266, 271-72 (1994). To state a substantive due process claim, a plaintiff must “show both a deprivation of [his] liberty and conscience shocking behavior by the government.” 3 - ORDER TO DISMISS Brittain, 451 F.3d at 991. However, “where a particular amendment provides an explicit textual source of constitutional protection against a particular sort of government behavior, that Amendment, not the more generalized notion of substantive due process, must be the guide for analyzing a plaintiff’s claims.” Patel v. Penman, 103 F.3d 868, 874 (9th Cir. 1996) (citations,

internal quotations, and brackets omitted) overruled on other grounds by Unitherm Food Systems, Inc. v. Swift-Eckrick, Inc., 546 U.S. 394 (2006); Lewis, 523 U.S. at 842. Here, plaintiff’s allegations implicate the Fourth Amendment right to be free from unlawful search and seizure, and plaintiff may not purse a substantive due process claim. Buford v. Mounts, Case No. CVF026187OWW DLB P, 2006 WL 657035, at *4 (E.D. Cal. March 13, 2006). Although plaintiff does not specifically invoke his Fourth Amendment rights, “[t]he impoundment of an automobile is a seizure within the meaning of the Fourth Amendment.” Ramirez

v. Buena Park, 560 F.3d 1012, 1024 (9th Cir. 2009) (quoting Miranda v. City of Cornelius, 429 F.3d 858, 862 (9th Cir. 2005)). A seizure conducted without a warrant is per se unreasonable under the Fourth Amendment subject only to a few specifically established exceptions. Ramirez, 560 F.3d at 1025.

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West v. Atkins
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Albright v. Oliver
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Patel v. Penman
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Lopez v. Smith
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Burns v. County of King
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Ogden v. Ontario Oregon City Police Dept, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ogden-v-ontario-oregon-city-police-dept-ord-2021.