(PS) Creel v. Sacramento County Sheriff Department

District Court, E.D. California·Decided June 20, 2025·No. 2:24-cv-01533·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 CHAD MICHAEL CREEL, No. 2:24-cv-01533-KJM-SCR 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 SACRAMENTO COUNTY SHERIFF DEPARTMENT, et al., 15 Defendants. 16 17 Plaintiff is proceeding pro se in this action, which was accordingly referred to the 18 undersigned by operation of Local Rule 302(c)(21). Plaintiff sues over a January 8, 2024 incident 19 during which Sacramento County Sheriff’s deputies allegedly detained and groped him in 20 violation of his constitutional rights. He proceeds on the Second Amended Complaint. ECF No. 21 8. Before the Court is Defendant Jim Cooper’s and Defendant Sacramento County Sheriff’s 22 Department’s motion to dismiss. ECF No. 12. Opposition and reply briefs were filed. ECF Nos. 23 17 & 18. The Court heard argument on the motion on June 12, 2025. The Court also discussed 24 with the parties the identities of the two unnamed deputies involved in the January 8, 2025 25 incident. The Court recommends GRANTING the motion to dismiss and dismissing the Monell 26 claims against the Sacramento County Sheriff’s Department and Sheriff Jim Cooper without 27 leave to amend but allowing Plaintiff to file a Third Amended Complaint to name one or both of 28 deputies involved in the incident. 1 I. Background and Procedural History 2 Plaintiff filed his complaint and a request to proceed in forma pauperis on May 31, 2024. 3 ECF Nos. 1 & 2. On November 5, 2024, the Court issued an order granting leave to proceed IFP, 4 found the complaint failed to state a claim, and granted leave to amend. ECF No. 5. Plaintiff 5 filed a first amended complaint (“FAC”) on December 6, 2024. ECF No. 6. The Court screened 6 the FAC, found the FAC failed to state a claim, and granted leave to amend. ECF No. 7. On 7 February 26, 2025, Plaintiff filed the operative second amended complaint (“SAC”). ECF No. 8. 8 The SAC alleges violation of his First and Fourth Amendment rights. Plaintiff contends 9 he was subjected to unlawful detention in retaliation for “flashing his middle finger” at officers. 10 ECF No. 8 at 7. Plaintiff alleges he was searched without consent, and that one of the officers 11 “groped” his genital area. Id. Plaintiff alleges the date the events occurred, January 8, 2024, and 12 that they occurred in a recreational vehicle park where Plaintiff was living. Id. 13 The SAC names as Defendants: 1) the Sacramento County Sheriff’s Department 14 (“SCSD”); 2) Sheriff Jim Cooper; 3) Deputy Sheriff #1; and 4) Deputy Sheriff #2. ECF No. 8 at 15 2-3. SCSD and Cooper have filed a motion to dismiss arguing that Plaintiff fails to state a 16 municipal liability claim against SCSD, and that the claim against Cooper is duplicative because 17 he is sued only in his official capacity. ECF No. 12 at 2. 18 II. Legal Standards 19 Defendants SCSD and Cooper move to dismiss on the basis of Rule 12(b)(6). The purpose 20 of a motion to dismiss pursuant to Rule 12(b)(6) is to test the legal sufficiency of the complaint. N. 21 Star Int’l v. Ariz. Corp. Comm’n, 720 F.2d 578, 581 (9th Cir. 1983). “Dismissal can be based on 22 the lack of a cognizable legal theory or the absence of sufficient facts alleged under a cognizable 23 legal theory.” Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). A plaintiff is 24 required to allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. 25 Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the plaintiff 26 pleads factual content that allows the court to draw the reasonable inference that the defendant is 27 liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 28 In determining whether a complaint states a claim on which relief may be granted, the court 1 accepts as true the allegations in the complaint and construes the allegations in the light most 2 favorable to the plaintiff. Hishon v. King & Spalding, 467 U.S. 69, 73 (1984). However, the court 3 need not assume the truth of legal conclusions cast in the form of factual allegations. U.S. ex rel. 4 Chunie v. Ringrose, 788 F.2d 638, 643 n.2 (9th Cir. 1986). While Rule 8(a) does not require 5 detailed factual allegations, “it demands more than an unadorned, the-defendant-unlawfully- 6 harmed-me accusation.” Iqbal, 556 U.S. at 678. A pleading is insufficient if it offers mere “labels 7 and conclusions” or “a formulaic recitation of the elements of a cause of action.” Twombly, 550 8 U.S. at 555; see also Iqbal, 556 U.S. at 678 (“Threadbare recitals of the elements of a cause of 9 action, supported by mere conclusory statements, do not suffice.”). It is inappropriate to assume 10 that the plaintiff “can prove facts that it has not alleged or that the defendants have violated the ... 11 laws in ways that have not been alleged.” Associated Gen. Contractors of Cal., Inc. v. Cal. State 12 Council of Carpenters, 459 U.S. 519, 526 (1983). 13 III. Analysis 14 A. Monell Liability & Supervisory Liability 15 “[M]unicipalities and other local government units … [are] among those persons to whom 16 § 1983 applies.” Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 690 (1978). Counties are also 17 persons for purposes of § 1983. See Jackson v. Barnes, 749 F.3d 755, 764 (9th Cir. 2014) 18 (“[W]hen a California sheriff’s department performs the function of conducting criminal 19 investigations, it is a county actor subject to suit under § 1983.”). “In order to establish municipal 20 liability, a plaintiff must show that a ‘policy or custom’ led to the plaintiff’s injury.” Castro v. 21 County of Los Angeles, 833 F.3d 1060, 1073 (9th Cir. 2016) (en banc). 22 As for supervisory liability, “a supervisor is only liable for the constitutional violations of 23 subordinates “if the supervisor participated in or directed the violations, or knew of the violations 24 and failed to act to prevent them. There is no respondeat superior liability under § 1983.” Taylor 25 v. List, 880 F.2d 1040, 1045 (9th Cir. 1989). “An official may be liable as a supervisor only if 26 either (1) he or she was personally involved in the constitutional deprivation, or (2) a sufficient 27 causal connection exists between the supervisor’s wrongful conduct and the constitutional 28 violation.” Felarca v. Birgeneau, 891 F.3d 809, 819–20 (9th Cir. 2018). This causal connection 1 can be established “by setting in motion a series of acts by others or by knowingly refus[ing] to 2 terminate a series of acts by others, which [the supervisor] knew or reasonably should have 3 known would cause others to inflict a constitutional injury.” Rodriguez v. County of Los Angeles, 4 891 F.3d 776, 798 (9th Cir. 2018).

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

(PS) Creel v. Sacramento County Sheriff Department, (E.D. Cal. 2025).

(PS) Creel v. Sacramento County Sheriff Department ((PS) Creel v. Sacramento County Sheriff Department) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related