(PS) Huber v. Fisher

CourtDistrict Court, E.D. California
DecidedAugust 22, 2025
Docket2:25-cv-01311
StatusUnknown

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

Bluebook
(PS) Huber v. Fisher, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 HERBERT HUBER, No. 2:25-cv-1311-DC-CKD (PS) 12 Plaintiff, 13 v. ORDER 14 FISHER, et al., 15 Defendants. 16

17 18 Plaintiff Herbert Huber proceeds without counsel and seeks relief for alleged violations of 19 his federal civil rights based on the seizure of his vehicle. This matter is before the undersigned 20 pursuant to Local Rule 302(c)(21). See 28 U.S.C. § 636(b)(1). 21 Plaintiff’s complaint filed on May 7, 2025 (ECF No. 1) is before the court for screening. 22 Plaintiff has also filed an application in support of a request to proceed in forma pauperis. (ECF 23 No. 2.) The application makes the showing required by 28 U.S.C. § 1915. The motion to proceed 24 in forma pauperis is granted. The complaint states a Fourth Amendment claim against defendant 25 Fisher only. Plaintiff is granted leave to file an amended complaint. In the alternative, plaintiff 26 may proceed on the claim against defendant Fisher without amending by voluntarily dismissing 27 the other claims and defendants. 28 1 I. Screening Requirement 2 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 3 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a 4 claim on which relief may be granted,” or “seeks monetary relief against a defendant who is 5 immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 6 (2000). In reviewing a complaint under this standard, the court accepts as true the factual 7 allegations contained in the complaint, unless they are clearly baseless or fanciful, and construes 8 those allegations in the light most favorable to the plaintiff. See Neitzke, 490 U.S. at 327; Von 9 Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960 (9th Cir. 2010), cert. 10 denied, 564 U.S. 1037 (2011). 11 II. Plaintiff’s Allegations 12 On May 29, 2023, defendant Fisher, a California State Parks Police Officer, ordered 13 plaintiff’s vehicle towed citing it as “CVC 4000 ‘unregistered.’” (ECF No. 1 at 2.) However, 14 plaintiff’s registration was current, with all fees paid, and a valid sticker of proof was displayed 15 on the rear license plate which Fisher scraped off. (Id. at 2, 4-5, 7.) The car did not present any 16 hazard or obstruct traffic and there were no exigent circumstances. (Id.) 17 Defendant Fisher claimed he “called it in” and was told plaintiff’s car was unregistered. 18 (ECF No. 1 at 7.) However, defendant Fisher had recognized plaintiff’s car as a homeless 19 person’s car and targeted it for that reason. (Id. at 4-5.) Plaintiff was left stranded with no safe 20 overnight lodging and without access to medications. (Id.) Subsequently, Officer Josh 21 acknowledged the error and that plaintiff’s car was properly registered, but Superintendent 22 Howard refused to recognize error and blamed DMV. (Id. at 8.) Plaintiff asserts violations of his 23 Fourth and Fourteenth Amendment rights based on the seizure. (Id. at 4-5, 7.) 24 III. Discussion 25 To state a claim under the Civil Rights Act, 42 U.S.C. § 1983, a plaintiff must allege two 26 essential elements: (1) a right secured by the Constitution or laws of the United States was 27 violated, and (2) the alleged violation was committed by a person acting under the color of state 28 law. West v. Atkins, 487 U.S. 42, 48 (1988). Here, the complaint adequately alleges defendants 1 acted under color of state law. The court considers below whether plaintiff has alleged an 2 unreasonable seizure under the Fourth Amendment or a violation of procedural due process or 3 equal protection under the Fourteenth Amendment. 4 A. Fourth Amendment 5 The Fourth Amendment protects the “right of people to be secure in their persons, houses, 6 papers, and effects, against unreasonable searches and seizures.” U.S. CONST. amend. IV. A 7 seizure of property occurs when there is some meaningful interference with an individual’s 8 possessory interests in that property. Soldal v. Cook County, Ill., 506 U.S. 56, 61 (1992). “The 9 impoundment of an automobile is a seizure within the meaning of the Fourth Amendment.” 10 Miranda v. City of Cornelius, 429 F.3d 858, 862 (9th Cir. 2005). 11 “A seizure conducted without a warrant is per se unreasonable under the Fourth 12 Amendment—subject only to a few specifically established and well delineated exceptions. The 13 burden is on the Government to persuade the district court that a seizure comes under one of a 14 few specifically established exceptions to the warrant requirement.” United States v. Hawkins, 15 249 F.3d 867, 872 (9th Cir. 2001) (internal quotation marks and citations omitted). 16 Drawing all permissible inferences in plaintiff’s favor, the complaint alleges a violation of 17 plaintiff’s Fourth Amendment rights by defendant Fisher. However, the allegations do not suffice 18 to state a claim against any other defendant. There can be no liability under 42 U.S.C. § 1983 19 unless there is some affirmative link or connection between a defendant’s actions and the claimed 20 deprivation. Rizzo v. Goode, 423 U.S. 362 (1976). Plaintiff does not allege facts showing the 21 other defendants acted or failed to act in a way that caused the deprivation of plaintiff’s vehicle. 22 Instead, they are merely alleged to have failed to remedy the situation after the deprivation 23 occurred. Contrary to plaintiff’s assertion, liability may not be imposed on supervisory personnel 24 under the theory of respondeat superior. See Ashcroft v. Iqbal, 556 U.S. 662, 676-77 (2009). 25 B. Fourteenth Amendment 26 1. Due Process 27 The Fourteenth Amendment prohibits any state from depriving “any person of life, liberty, 28 or property, without due process of law.” U.S. CONST. amend XIV, § 1. Determination of what 1 process is due is a fact-specific inquiry requiring consideration of three factors: 2 [1] the private interest that will be affected by the official action; [2] the risk of an erroneous deprivation of such interest through the 3 procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and [3] the Government’s 4 interest… 5 Mathews v. Eldridge, 424 U.S. 319, 335 (1976). 6 However, unauthorized and intentional deprivations of property, as alleged here, do not 7 constitute a violation of procedural requirements of the Due Process Clause if a meaningful post- 8 deprivation remedy for the loss is available. See Hudson v. Palmer, 468 U.S. 517, 533 (1984).

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

Related

Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Mathews v. Eldridge
424 U.S. 319 (Supreme Court, 1976)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
City of Cleburne v. Cleburne Living Center, Inc.
473 U.S. 432 (Supreme Court, 1985)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Soldal v. Cook County
506 U.S. 56 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
United States v. David R. Hawkins
249 F.3d 867 (Ninth Circuit, 2001)
Von Saher v. Norton Simon Museum of Art at Pasadena
592 F.3d 954 (Ninth Circuit, 2010)
Skelly Oil Co. v. Federal Power Commission
375 F.2d 6 (Tenth Circuit, 1967)

Cite This Page — Counsel Stack

Bluebook (online)
(PS) Huber v. Fisher, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-huber-v-fisher-caed-2025.