Pelton v. Amador

District Court, N.D. California·Decided December 12, 2024·No. 5:22-cv-02027·Unknown

Opinion

SEAN MICHAEL PELTON, Case No. 22-cv-02027-EKL

Plaintiff, ORDER OF SERVICE v.

RICHARD AMADOR, et al., Defendants.

Plaintiff, a detainee, filed a pro se civil rights complaint under 42 U.S.C. § 1983 and the Stored Communications Act. Plaintiff alleges that a South San Francisco detective violated his Fourth Amendment rights during his arrest. Plaintiff was granted leave to proceed in forma pauperis (ECF No. 2) and the original complaint was dismissed with leave to amend (ECF No. 9). It was clear from the amended complaint, that the alleged Fourth Amendment violations were related to the criminal charges that were pending against plaintiff at that time. ECF No. 13 at 1. Therefore, this federal case was stayed pursuant to Wallace v. Kato, 549 U.S. 384, 393-94 (2007), until the criminal charges were resolved. ECF No. 13 at 1-2. Plaintiff filed a notice stating that the criminal charges had been dismissed. ECF No. 17. The stay was lifted, and the case was reassigned to the undersigned. ECF Nos. 22, 23. Standard of Review Federal courts engage in a preliminary screening of cases in which prisoners seek redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). In its review, the Court must identify any cognizable claims and dismiss any claims monetary relief from a defendant who is immune from such relief. Id. at § 1915A(b)(1), (2). Pro se pleadings must be liberally construed. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the claim showing that the pleader is entitled to relief.” Although a complaint “does not need detailed factual allegations, . . . a plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment] to relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do . . . . Factual allegations must be enough to raise a right to relief above the speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations omitted). A complaint must proffer “enough facts to state a claim to relief that is plausible on its face.” Id. at 570. The Supreme Court has explained the “plausible on its face” standard of Twombly: “While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations. When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). To state a claim under 42 U.S.C. § 1983, a plaintiff must allege that: (1) a right secured by the Constitution or laws of the United States was violated, and (2) the alleged deprivation was committed by a person acting under the color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). Liability may be imposed on an individual defendant under 42 U.S.C. § 1983 if the plaintiff can show that the defendant’s actions actually and proximately caused the deprivation of a federally protected right. Lemire v. California Dep’t of Corrections & Rehabilitation, 726 F.3d 1062, 1074 (9th Cir. 2013); Leer v. Murphy, 844 F.2d 628, 634 (9th Cir. 1988). A person deprives another of a constitutional right within the meaning of Section 1983 if he does an affirmative act, participates in another’s affirmative act or fails to perform an act which he is legally required to do, that causes the deprivation of which the plaintiff complains. Id. at 633. Plaintiff’s Allegations Plaintiff states that on February 9, 2018, defendant Detective Amador from the South San Plaintiff provided consent to search certain items and later Amador obtained a search warrant, but plaintiff argues that Amador went beyond the consent and the terms of the search warrant in obtaining other information from plaintiff’s phones and online accounts. Id. at 2-4. The information obtained from the illegal search led to multiple arrests. Id. at 3. Plaintiff also alleges that Amador’s training was deficient and other people have had files illegally downloaded from their phones by the South San Francisco Police. Id. at 4. Plaintiff asserts that South San Francisco Police Chief Scott Campbell and the City of South San Francisco are liable for these constitutional violations. Id. at 4-5. Analysis The Fourth Amendment to the United States Constitution guarantees freedom from unreasonable search and seizure. U.S. Const. amend. IV. The “ultimate touchstone of the Fourth Amendment is reasonableness.” Riley v. California, 573 U.S. 373, 381-82 (2014) (internal citation omitted). In Riley, the Supreme Court held that a warrant is generally required to search a cell phone seized incident to arrest. Id. at 403. In so holding, the Supreme Court recognized that modern cell phones are “a pervasive and insistent part of daily life” with “vast quantities of personal information” that “hold for many Americans ‘the privacies of life.’” Id. at 385, 386, 403. The Stored Communications Act under the Electronic Communications Privacy Act makes it an offense to “intentionally access[ ] without authorization a facility through which an electronic communication service is provided . . . and thereby obtain[ ] . . . access to a wire or electronic communication while it is in electronic storage in such system.” Konop v. Hawaiian Airlines, 302 F.3d 868, 879 (9th Cir. 2002) (citing 18 U.S.C. § 2701(a)(1)). A supervisor may be liable under Section 1983 upon a showing of (1) personal involvement in the constitutional deprivation or (2) a sufficient causal connection between the supervisor’s wrongful conduct and the constitutional violation. Henry A. v. Willden, 678 F.3d 991, 1003-04 (9th Cir. 2012). Even if a supervisory official is not directly involved in the allegedly unconstitutional conduct, “[a] supervisor can be liable in this individual capacity for his own culpable action or inaction in the training, supervision, or control of his subordinates; for his indifference to the rights of others.” Starr v. Baca, 652 F.3d 1202, 1208 (9th Cir. 2011) (citation omitted). “[A] local government may not be sued under § 1983 for an injury inflicted solely by its employees or agents. Instead, it is when execution of a government’s policy or custom, whether made by its lawmakers or by those whose edicts or acts may fairly be said to represent official policy, inflicts the injury that the government as an entity is responsible under § 1983.” Monell v. Dep’t of Social Servs., 436 U.S. 658, 694 (1978). To impose municipal liability under Section 1983 for a violation of constitutional rights resulting from governmental inaction or omission,

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