(PS) Crago v. Sacramento County Towing Enforcement Supervisor

District Court, E.D. California·Decided August 21, 2025·No. 2:25-cv-00086·Unknown

Opinion

1 2 3 4 5 6 7 10 11 MARY CRAGO, No. 2:25-cv-00086-DC-CKD PS 12 Plaintiff, 13 v. FINDINGS & RECOMMENDATION 14 SACRAMENTO COUNTY TOWING 15 ENFORCEMENT SUPERVISOR, et. al., 16 Defendants. 17 18 Plaintiff Mary Crago proceeds without counsel in this action.1 On March 28, 2025, the 19 Court issued an order dismissing plaintiff’s complaint with leave to amend and granting plaintiff 20 thirty (30) days to file an amended complaint. (ECF No. 6.) Plaintiff filed a first amended 21 complaint (“FAC”) on May 29, 2025, which is now before the Court for screening. (ECF No. 9.) 22 Plaintiff’s FAC fails to state a claim. For the reasons set forth below, the FAC should be 23 dismissed without leave to amend. 24 I. Screening Requirement 25 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 26 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a 27 1 Actions in which a party proceeds without counsel are referred to a magistrate judge pursuant to 28 E.D. Cal. L.R. 302(c)(21). See 28 U.S.C. § 636(b)(1) and Fed. R. Civ. P. 72. 1 claim on which relief may be granted,” or “seeks monetary relief against a defendant who is 2 immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 3 (2000). A claim is legally frivolous when it lacks an arguable basis either in law or in fact. 4 Neitzke v. Williams, 490 U.S. 319, 325 (1989). In reviewing a complaint under this standard, the 5 court accepts as true the factual allegations contained in the complaint, unless they are clearly 6 baseless or fanciful, and construes those allegations in the light most favorable to the plaintiff. 7 See Neitzke, 490 U.S. at 327; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 8 954, 960 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011). 9 Pro se pleadings are held to a less stringent standard than those drafted by lawyers. Haines 10 v. Kerner, 404 U.S. 519, 520 (1972). However, the court need not accept as true conclusory 11 allegations, unreasonable inferences, or unwarranted deductions of fact. Western Mining Council 12 v. Watt, 643 F.2d 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of 13 action does not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 14 (2007); Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 15 To state a claim on which relief may be granted, the plaintiff must allege enough facts “to 16 state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has facial 17 plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable 18 inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. A pro se 19 litigant is entitled to notice of the deficiencies in the complaint and an opportunity to amend 20 unless the complaint’s deficiencies could not be cured by amendment. See Noll v. Carlson, 809 21 F.2d 1446, 1448 (9th Cir. 1987), superseded on other grounds by statute as stated in Lopez v. 22 Smith, 203 F.3d 1122 (9th Cir. 2000) (en banc). 23 II. Plaintiff’s Allegations 24 Plaintiff alleges the Sacramento Sheriff towed her truck and RV from Napa Auto Parts. 25 (ECF No. 9 at 29.) Plaintiff states she was shopping in the store and the Napa Auto Parts 26 employee did not ask her to leave. (Id. at 30.) Plaintiff states she was not trespassing. (Id. at 29.) 27 She states she had a valid registration card and was willing to leave the store, and also states that 28 her license was expired. (Id.) The vehicles were towed to two different tow yards which caused 1 “excessive fines.” (Id. at 29-30.) Plaintiff also alleges that “internal affairs” failed to investigate a 2 citizen’s complaint she sent by email. (Id. at 28.) 3 Plaintiff alleges a violation of her federal civil rights. (Id. at 4.) The defendants named in 4 the complaint are Internal Affairs; Sacramento Sheriffs; Sacramento Towing Enforcement; Super 5 Tow; Super Tow’s general liability insurance company; College Oak Tow; College Oak Tow’s 6 general liability insurance company; Napa Auto Parts; and Napa Auto Parts general liability 7 insurance company. (Id. at 19-20.) 8 III. The FAC fails to state a claim. 9 The FAC still does not contain a short and plain statement of a claim as required by 10 Federal Rule of Civil Procedure 8. In order to give fair notice of the claims and the grounds on 11 which they rest, a plaintiff must allege with at least some degree of particularity overt acts by 12 specific defendants which support the claims. See Kimes v. Stone, 84 F.3d 1121, 1129 (9th Cir. 13 1996). To state a claim under the Civil Rights Act, 42 U.S.C. § 1983, a plaintiff must allege two 14 essential elements: (1) that a right secured by the Constitution or laws of the United States was 15 violated, and (2) that the alleged violation was committed by a person acting under the color of 16 state law. West v. Atkins, 487 U.S. 42, 48 (1988). The court considers below whether plaintiff has 17 alleged an unreasonable seizure under the Fourth Amendment, a violation of Excessive Fines 18 Clause of the Eighth Amendment, or a Due Process violation to meet the essential elements for a 19 claim under the Civil Rights Act. 20 A. Fourth Amendment 21 The Fourth Amendment protects the “right of people to be secure in their persons, houses, 22 papers, and effects, against unreasonable searches and seizures.” U.S. CONST. amend. IV. A 23 seizure of property occurs when there is some meaningful interference with an individual’s 24 possessory interests in that property. Soldal v. Cook County, Ill., 506 U.S. 56, 61 (1992). The 25 impoundment of plaintiff’s vehicle was a seizure within the meaning of the Fourth Amendment. 26 Police officers are permitted to impound vehicles pursuant to the community caretaker 27 exception to the Fourth Amendment. South Dakota v. Opperman, 428 U.S. 364, 368 (1976). 28 Whether a vehicle may be impounded under the community caretaking doctrine “depends on the 1 location of the vehicle and the police officer’s duty to prevent it from creating a hazard to other 2 drivers or from being a target for vandalism or theft.” United States v. Caseres, 533 F.3d 1064, 3 1075 (9th Cir. 2008); Hallstrom v. Garden City, 991 F.2d 1473, 1477 n.4 (9th Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

(PS) Crago v. Sacramento County Towing Enforcement Supervisor, (E.D. Cal. 2025).

(PS) Crago v. Sacramento County Towing Enforcement Supervisor ((PS) Crago v. Sacramento County Towing Enforcement Supervisor) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
South Dakota v. Opperman
428 U.S. 364 (Supreme Court, 1976)
Illinois v. Lafayette
462 U.S. 640 (Supreme Court, 1983)
Colorado v. Bertine
479 U.S. 367 (Supreme Court, 1987)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Soldal v. Cook County
506 U.S. 56 (Supreme Court, 1992)
Austin v. United States
509 U.S. 602 (Supreme Court, 1993)
United States v. Bajakajian
524 U.S. 321 (Supreme Court, 1998)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Family Winemakers of California v. Jenkins
592 F.3d 1 (First Circuit, 2010)
Western Mining Council v. Watt
643 F.2d 618 (Ninth Circuit, 1981)
Gomez v. Whitney
757 F.2d 1005 (Ninth Circuit, 1985)
United States v. Caseres
533 F.3d 1064 (Ninth Circuit, 2008)
Zinermon v. Burch
494 U.S. 113 (Supreme Court, 1990)