Pifferini v. City of Eureka

CourtDistrict Court, N.D. California
DecidedAugust 4, 2025
Docket1:24-cv-09191
StatusUnknown

This text of Pifferini v. City of Eureka (Pifferini v. City of Eureka) 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
Pifferini v. City of Eureka, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 EUREKA DIVISION 7 8 KELLY SHANE PIFFERINI, Case No. 24-cv-09191-RMI

9 Plaintiff, ORDER ON MOTION TO DISMISS 10 v. Re: Dkt. No. 16 11 CITY OF EUREKA, et al., 12 Defendants.

13 Now pending before the court is the motion (Dkt. 16) of Defendants City of Eureka, Brian 14 Stevens, Victoria Graham, and Jon Omey1 to dismiss Plaintiff Kelly Shane Pifferini’s complaint 15 (dkt. 1), and for clarification. Pursuant to Federal Rule of Civil Procedure 78(b) and Civil Local 16 Rule 7-1(b), the court finds the matter suitable for disposition without oral argument. For the 17 reasons stated below, Defendants’ motion to dismiss is GRANTED IN PART AND DENIED IN 18 PART, and their motion for clarification is DENIED. 19 I. Background2 20 Plaintiff is an unhoused resident of Eureka, California (“the City”). (Dkt. 1, p. 2). He 21 “ha[s] no access to anywhere but public areas at all times” and cannot access indoor shelter or 22 available public storage. Id. Accordingly, he and his possessions must be in public at all times. 23 Id. 24

25 1 Officer Graham’s name is spelled “Grham” in the complaint, and Sergeant Omey’s name is spelled “Omme.” (Dkt. 1, p. 3). This order uses the spelling these Defendants use in their motion 26 to dismiss.

27 2 For purposes of a motion to dismiss, “[a]ll allegations of material fact are taken as true and 1 In 2019, the Ninth Circuit decided Martin v. City of Boise, 920 F.4th 584. Martin held that 2 “the Eighth Amendment prohibits the imposition of criminal penalties for sitting, sleeping, or 3 lying outside on public property for homeless individuals who cannot obtain shelter.” Id. at 616. 4 In response, the Eureka City Council amended its public camping laws. (Dkt. 1, p. 5). The 5 resulting ordinance, Eureka Municipal Code (“E.M.C.”) § 93.02, forbids involuntary camping3 at 6 certain specified locations.4 E.M.C. §§ 93.02(B), (C)(2).5 It provides that “[i]nvoluntary camping 7 on public property is lawful when and where it is not otherwise unlawful” under the statute’s 8 provisions. Id. § 93.02(D). 9 However, E.M.C. § 93.02 does not go so far as to specifically designate the areas where 10 involuntary camping is lawful. Indeed, the ordinance specifically declines to do so, stating that 11 “[t]here is no specific site or sites that should be designated for camping because it is the 12 experience of the city and other municipalities that sites where camping is continuous or camping 13 populations are numerous become public health, environmental degradation, and policing 14 problems.” Id. § 93.02(A)(2). Plaintiff alleges that while the City Council said it would “add 15 precise coordinates to the borders and boundaries of the[] prohibited areas, and would supply 16 maps to show these locations[,]” it said it “would also make public statements that there would be 17 no designated borders and boundaries for the portions of the public space where camping would 18 be tolerated, and that no maps would be made of these legal camping areas.” (Dkt. 1, p. 7). 19 Plaintiff alleges that this leaves “all citizens clueless as to the whereabouts of these legal areas.” 20 Id. 21 Further, Plaintiff alleges that “police treat more than just the prohibited areas as unlawful 22 for camping[]” and “enforce [camping in] all public areas as unlawful.” (Dkt. 1, p. 7). Plaintiff 23 claims that to prevent officers from directing campers to legal camping sites, the City refuses to 24 3 “Camping by a person at such time as there is no accommodation accepting homeless persons 25 within the city that is available for that same person.” E.M.C. § 93.02(B).

26 4 These include city parks, certain business districts, and areas within 75 feet of recreational trails. E.M.C. § 93.02(B). 27 1 tell the police where the legal camping sites are. Id. at 8. Plaintiff further claims that the City 2 “instruct[s] police to tell unhoused citizens that there is nowhere in Eureka where camping is 3 legal.” Id. at 9. Plaintiff asserts that the “city council was fully aware that the rules and 4 regulations would never get to be used by any body [sic] and that this way nobody would ever be 5 able to gain access to a portion of public where any type of camping could take place.” Id. at 7–8. 6 Indeed, Plaintiff claims that “not a single person has ever been aloud [sic] by the police to actually 7 involuntarily camp.” Id. at 9. Therefore, Plaintiff alleges that the City’s passage and enforcement 8 of E.M.C. § 93.02 has violated his Eighth Amendment rights under Martin. Id. at 8. 9 Plaintiff states that Officer Graham “harassed” him for violations of E.M.C. § 93.02, which 10 he says is “a common EPD practice.” (Dkt. 1, p. 12). Further, he alleges that Officer Graham has 11 never offered him shelter during these encounters “because all of our encounters occurred before 12 5pm, and there is no sheltering service open until 5pm everyday.” Id. 13 Plaintiff also takes issue with another Eureka ordinance, E.M.C. § 130.14. This ordinance 14 forbids storage of personal property in public areas. E.M.C. § 130.14(C). The ordinance defines 15 “store” as “to put aside or accumulate for use when needed, to put for safekeeping, and/or to place 16 or leave in a location.” Id. §130.14(B). Under the ordinance, “[p]ersonal property placed in 17 public areas shall be deemed to be stored personal property if it has not been removed from public 18 areas within 24 hours of service of written notice, requiring such removal.” Id. § 130.14(C)(3). 19 However, “[m]oving personal property to another location in a public area or returning personal 20 property to the same block on a daily or regular basis” is not considered removal. Id. Such 21 property may be removed and impounded after the 24 hours have passed. Id. 22 E.M.C. § 130.14 contains some exceptions to the general rule. Property left within 10 feet 23 of entrances, exits, driveways, and loading docks may be removed without prior notice if post- 24 removal notice is given. Id. § 130.14(C)(4). The same is true of property left in an area with a 25 posted closure time after the area has closed. § 130.14(C)(5). Contraband and evidence of crimes 26 may be immediately removed without prior notice. Id. § 130.14(C)(8). Property which poses “an 27 1 immediate threat to the health or safety of the public” or is “bulky”6 may be immediately removed 2 without prior notice and discarded. Id. § 130.14(C)(6)–(7). 3 Both pre- and post-removal notices under § 130.14 must contain “[t]he location where the 4 removed personal property will be” stored or located, “including a telephone number and internet 5 website of the city through which a person may receive information as to impounded personal 6 property[.]” E.M.C. §§ 130.14(D)(1)(g), (D)(2)(d). Pre-removal notices must also state “that the 7 personal property will be impounded if not removed from public areas within 24 hours.” Id. § 8 130.14(D)(1)(d). Impounded property “shall be stored by the city for 90 days” and notices must 9 state that the property may be discarded after that time. Id. §§ 130.14(D)(1)(h), D(2)(e), (F)(2). 10 Plaintiff alleges that § 130.14 “allows police officers to seize an unhoused person’s 11 property for simply using those items in a public place.” (Dkt. 1, p. 10). He states that “[whe]ther 12 those items are left unattended, or in a person’s possession, police can seize such property, and in 13 most cases immediately discard those items as trash.” Id. He states that the ordinance makes it 14 “unlawful for me to even part ways with my possessions long enough to even enter a building or 15 establishment” to shop, receive services, or appear in court. Id.

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Pifferini v. City of Eureka, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pifferini-v-city-of-eureka-cand-2025.