(PC) Rayburn v. California Highway Patrol

CourtDistrict Court, E.D. California
DecidedFebruary 6, 2025
Docket2:24-cv-02704
StatusUnknown

This text of (PC) Rayburn v. California Highway Patrol ((PC) Rayburn v. California Highway Patrol) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(PC) Rayburn v. California Highway Patrol, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 JESSE JAMES RAYBURN, No. 24-cv-02704 SCR P 12 Plaintiff, 13 v. ORDER 14 CALIFORNIA HIGHWAY PATROL, et al., 15 Defendants. 16 17 Plaintiff is a county prisoner in the state of Arkansas proceeding pro se in this civil rights 18 action under 42 U.S.C. § 1983. He has requested leave to proceed without paying the full filing 19 fee for this action, under 28 U.S.C. § 1915. Plaintiff has submitted a declaration showing that he 20 cannot afford to pay the entire filing fee and a certified copy of the trust fund account statement 21 for the six-month period immediately preceding the filing of the complaint. See 28 U.S.C. 22 § 1915(a)(2). Accordingly, plaintiff’s motion to proceed in forma pauperis is granted. However, 23 the court finds plaintiff’s first amended complaint (“FAC”) is legally deficient and will grant 24 Plaintiff an opportunity to file an amended complaint. 25 I. SCREENING 26 A. Legal Standard 27 The court is required to screen complaints brought by prisoners seeking relief against “a 28 governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A(a). A 1 claim is legally frivolous when it lacks an arguable basis either in law or in fact. Neitzke v. 2 Williams, 490 U.S. 319, 325 (1989). The court may dismiss a claim as frivolous if it is based on 3 an indisputably meritless legal theory or factual contentions that are baseless. Neitzke, 490 U.S. 4 at 327. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an 5 arguable legal and factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989). 6 To avoid dismissal for failure to state a claim a complaint must contain more than “naked 7 assertions,” “labels and conclusions” or “a formulaic recitation of the elements of a cause of 8 action.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-557 (2007). In other words, 9 “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory 10 statements do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A claim upon which the 11 court can grant relief has facial plausibility. Twombly, 550 U.S. at 570. “A claim has facial 12 plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable 13 inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. When 14 considering whether a complaint states a claim, the court must accept the allegations as true, 15 Erickson v. Pardus, 551 U.S. 89, 93-94 (2007), and construe the complaint in the light most 16 favorable to the plaintiff, Scheuer v. Rhodes, 416 U.S. 232, 236 (1974). 17 B. Procedural History 18 Plaintiff initiated the action in the U.S. District Court, Western District of Arkansas, 19 naming six defendants. See Rayburn v. West Siloam Springs Police, Case No. 5:24-cv-05203 20 (W.D. Ark.). On September 30, 2024, the assigned magistrate judge directed the Clerk of the 21 Court to sever the FAC’s claims against three of the defendants and split them into two new 22 cases: (1) Rayburn v. West Siloam Springs Police, Case No. 4:24-cv-00464 (N.D. Okla.); and (2) 23 Rayburn v. California Highway Patrol, et al., Case No. 2:24-cv-02704 (E.D. Cal.). (ECF No. 3.) 24 The FAC’s claims relevant to the latter action are now before the court for screening. 25 C. Factual Allegations of the FAC 26 Plaintiff’s FAC names the Lodi Police Department and California Highway Patrol 27 (“CHP”) as defendants. Both defendants are sued in their official capacity. (ECF No. 1 at 6.) 28 Plaintiff alleges that each time he was detained, the Lodi Police took his personal property 1 without a warrant. He lists five motor vehicles that he alleges the Lodi Police took from him: a 2 2009 Dodge Charger; a 2005 Buick; a 2009 Buick Enclave; a 2008 Volkswagen Jetta; and a 2015 3 Volkswagen Jetta. Plaintiff estimates that the vehicles taken by the Lodi Police Department have 4 a total value of “about $90,000.” (Id.) 5 The FAC alleges a claim for “deprivation of rights” against both defendants. (ECF No. 1 6 at 6.) Prompted by the complaint form to describe the policy or custom that caused the violation 7 of plaintiff’s constitutional rights, plaintiff’s FAC states “Constitution is a joke that we can use 8 the ignorance of the people to [steal] personal property.” (Id. at 7.) The FAC seeks 9 compensatory and punitive damages in the amount of $10,000,000. (Id. at 9-10.) 10 D. Analysis 11 The FAC does not identify the federal constitutional right that CHP and the Lodi Police 12 allegedly violated. However, the FAC’s first claim, which has been severed from this action (see 13 ECF No. 3), describes a different police department’s taking of his family’s vehicle as a 14 “deprivation of rights under color of law, 4th Amendment search and seizures.” (ECF No. 1 at 4.) 15 Considering the plaintiff’s pro se status and the factual similarities between the claims, the court 16 will broadly construe the FAC as raising a similar Fourth Amendment search and seizure claim 17 against CHP and Lodi Police Department and screen the FAC under 42 U.S.C. § 1983. 18 A plaintiff may bring an action under 42 U.S.C. § 1983 to redress violations of “rights, 19 privileges, or immunities secured by the Constitution and [federal] laws” by a person or entity, 20 including a municipality, acting under the color of state law. 42 U.S.C. § 1983. To state a claim 21 under 42 U.S.C. § 1983, a plaintiff must show that (1) a defendant acting under color of state law 22 (2) deprived plaintiff of rights secured by the Constitution or federal statutes. Benavidez v. 23 County of San Diego, 993 F.3d 1134, 1144 (9th Cir. 2021). 24 Because plaintiff has sued a municipal entity in its official capacity, he needs to satisfy the 25 42 U.S.C. § 1983 pleading requirements under the standard set forth in Monell v. Dep't of Soc. 26 Servs., 436 U.S. 658, 690 (1978). To properly plead a Monell claim based on an unconstitutional 27 custom, practice, or policy, plaintiff must show that the government “had a deliberate policy, 28 custom, or practice that was the moving force behind the constitutional violation [plaintiff] 1 suffered.” See AE ex rel. Hernandez v. County of Tulare, 666 F.3d 631, 636 (9th Cir. 2012) 2 (quotation marks and citation omitted).

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Related

Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Hafer v. Melo
502 U.S. 21 (Supreme Court, 1991)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ortiz-Pinero v. Rivera-Arroyo
84 F.3d 7 (First Circuit, 1996)
McFadden v. United States
923 F.2d 862 (Ninth Circuit, 1991)
AE Ex Rel. Hernandez v. County of Tulare
666 F.3d 631 (Ninth Circuit, 2012)
Javiad Akhtar v. J. Mesa
698 F.3d 1202 (Ninth Circuit, 2012)
Price v. Sery
513 F.3d 962 (Ninth Circuit, 2008)
Jonathon Castro v. County of Los Angeles
833 F.3d 1060 (Ninth Circuit, 2016)
John Benavidez v. County of San Diego
993 F.3d 1134 (Ninth Circuit, 2021)

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Bluebook (online)
(PC) Rayburn v. California Highway Patrol, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-rayburn-v-california-highway-patrol-caed-2025.