Pelton v. Amador

CourtDistrict Court, N.D. California
DecidedDecember 12, 2024
Docket5:22-cv-02027
StatusUnknown

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

Bluebook
Pelton v. Amador, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 SEAN MICHAEL PELTON, Case No. 22-cv-02027-EKL

8 Plaintiff, ORDER OF SERVICE v. 9

10 RICHARD AMADOR, et al., Defendants. 11

12 13 Plaintiff, a detainee, filed a pro se civil rights complaint under 42 U.S.C. § 1983 and the 14 Stored Communications Act. Plaintiff alleges that a South San Francisco detective violated his 15 Fourth Amendment rights during his arrest. Plaintiff was granted leave to proceed in forma 16 pauperis (ECF No. 2) and the original complaint was dismissed with leave to amend (ECF No. 9). 17 It was clear from the amended complaint, that the alleged Fourth Amendment violations were 18 related to the criminal charges that were pending against plaintiff at that time. ECF No. 13 at 1. 19 Therefore, this federal case was stayed pursuant to Wallace v. Kato, 549 U.S. 384, 393-94 (2007), 20 until the criminal charges were resolved. ECF No. 13 at 1-2. Plaintiff filed a notice stating that 21 the criminal charges had been dismissed. ECF No. 17. The stay was lifted, and the case was 22 reassigned to the undersigned. ECF Nos. 22, 23. 23 DISCUSSION 24 Standard of Review 25 Federal courts engage in a preliminary screening of cases in which prisoners seek redress 26 from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. 27 § 1915A(a). In its review, the Court must identify any cognizable claims and dismiss any claims 1 monetary relief from a defendant who is immune from such relief. Id. at § 1915A(b)(1), (2). Pro 2 se pleadings must be liberally construed. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 3 (9th Cir. 1990). 4 Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the 5 claim showing that the pleader is entitled to relief.” Although a complaint “does not need detailed 6 factual allegations, . . . a plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment] to 7 relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a 8 cause of action will not do . . . . Factual allegations must be enough to raise a right to relief above 9 the speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations 10 omitted). A complaint must proffer “enough facts to state a claim to relief that is plausible on its 11 face.” Id. at 570. The Supreme Court has explained the “plausible on its face” standard of 12 Twombly: “While legal conclusions can provide the framework of a complaint, they must be 13 supported by factual allegations. When there are well-pleaded factual allegations, a court should 14 assume their veracity and then determine whether they plausibly give rise to an entitlement to 15 relief.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). 16 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege that: (1) a right secured by 17 the Constitution or laws of the United States was violated, and (2) the alleged deprivation was 18 committed by a person acting under the color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). 19 Liability may be imposed on an individual defendant under 42 U.S.C. § 1983 if the 20 plaintiff can show that the defendant’s actions actually and proximately caused the deprivation of 21 a federally protected right. Lemire v. California Dep’t of Corrections & Rehabilitation, 726 F.3d 22 1062, 1074 (9th Cir. 2013); Leer v. Murphy, 844 F.2d 628, 634 (9th Cir. 1988). A person deprives 23 another of a constitutional right within the meaning of Section 1983 if he does an affirmative act, 24 participates in another’s affirmative act or fails to perform an act which he is legally required to 25 do, that causes the deprivation of which the plaintiff complains. Id. at 633. 26 Plaintiff’s Allegations 27 Plaintiff states that on February 9, 2018, defendant Detective Amador from the South San 1 Plaintiff provided consent to search certain items and later Amador obtained a search warrant, but 2 plaintiff argues that Amador went beyond the consent and the terms of the search warrant in 3 obtaining other information from plaintiff’s phones and online accounts. Id. at 2-4. The 4 information obtained from the illegal search led to multiple arrests. Id. at 3. Plaintiff also alleges 5 that Amador’s training was deficient and other people have had files illegally downloaded from 6 their phones by the South San Francisco Police. Id. at 4. Plaintiff asserts that South San Francisco 7 Police Chief Scott Campbell and the City of South San Francisco are liable for these constitutional 8 violations. Id. at 4-5. 9 Analysis 10 The Fourth Amendment to the United States Constitution guarantees freedom from 11 unreasonable search and seizure. U.S. Const. amend. IV. The “ultimate touchstone of the Fourth 12 Amendment is reasonableness.” Riley v. California, 573 U.S. 373, 381-82 (2014) (internal 13 citation omitted). In Riley, the Supreme Court held that a warrant is generally required to search a 14 cell phone seized incident to arrest. Id. at 403. In so holding, the Supreme Court recognized that 15 modern cell phones are “a pervasive and insistent part of daily life” with “vast quantities of 16 personal information” that “hold for many Americans ‘the privacies of life.’” Id. at 385, 386, 403. 17 The Stored Communications Act under the Electronic Communications Privacy Act makes 18 it an offense to “intentionally access[ ] without authorization a facility through which an electronic 19 communication service is provided . . . and thereby obtain[ ] . . . access to a wire or electronic 20 communication while it is in electronic storage in such system.” Konop v. Hawaiian Airlines, 302 21 F.3d 868, 879 (9th Cir. 2002) (citing 18 U.S.C. § 2701(a)(1)). 22 A supervisor may be liable under Section 1983 upon a showing of (1) personal 23 involvement in the constitutional deprivation or (2) a sufficient causal connection between the 24 supervisor’s wrongful conduct and the constitutional violation. Henry A. v. Willden, 678 F.3d 25 991, 1003-04 (9th Cir. 2012). Even if a supervisory official is not directly involved in the 26 allegedly unconstitutional conduct, “[a] supervisor can be liable in this individual capacity for his 27 own culpable action or inaction in the training, supervision, or control of his subordinates; for his 1 indifference to the rights of others.” Starr v. Baca, 652 F.3d 1202, 1208 (9th Cir. 2011) (citation 2 omitted). 3 “[A] local government may not be sued under § 1983 for an injury inflicted solely by its 4 employees or agents.

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