(PS) Jones v. City of Sacramento Board of Supervisors

CourtDistrict Court, E.D. California
DecidedMay 9, 2025
Docket2:25-cv-00864
StatusUnknown

This text of (PS) Jones v. City of Sacramento Board of Supervisors ((PS) Jones v. City of Sacramento Board of Supervisors) 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) Jones v. City of Sacramento Board of Supervisors, (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 RAHEEM JONES, et al., Case No. 2:25-cv-0864-DJC-JDP (PS) 12 Plaintiffs, 13 v. FINDINGS AND RECOMMENDATIONS 14 CITY OF SACRAMENTO BOARD OF SUPERVISORS, et al., 15 Defendants. 16

17 18 Plaintiffs Raheem Jones and Anthony Hall filed this action in Sacramento Superior Court 19 against the City of Sacramento Board of Supervisors and Sacramento City Police Department. 20 Before filing an answer, defendants removed this action on the basis of federal question 21 jurisdiction. Defendants have filed a motion to dismiss, and plaintiffs have filed a motion to 22 remand. For the reasons discussed below, I recommend that defendants’ motion be granted and 23 that plaintiffs motion be denied. 24 Motion to Remand 25 I. Legal Standard 26 A suit filed in state court may be removed if the federal court would have had original 27 jurisdiction over the suit. 28 U.S.C. § 1441(a). Removal is proper when a case originally filed in 28 1 state court presents a federal question or where there is diversity of citizenship among the parties 2 and the amount in controversy exceeds $75,000. See 28 U.S.C. §§ 1331, 1332(a). 3 “If at any time before final judgment it appears that the district court lacks subject matter 4 jurisdiction, the case shall be remanded.” 28 U.S.C. § 1447(c). “The removal statute is strictly 5 construed against removal jurisdiction, and the burden of establishing federal jurisdiction falls to 6 the party invoking the statute.” California ex rel. Lockyer v. Dynegy, Inc., 375 F.3d 831, 838 (9th 7 Cir. 2004) (citation omitted); see also Casola v. Dexcom, Inc., 98 F.4th 947, 954 (9th Cir. 2024); 8 Provincial Gov't of Marinduque v. Placer Dome, Inc., 582 F.3d 1083, 1087 (9th Cir. 2009) (“The 9 defendant bears the burden of establishing that removal is proper.”). If there is any doubt as to 10 the right of removal, a federal court must reject jurisdiction and remand the case to state court. 11 Matheson v. Progressive Specialty Ins. Co., 319 F.3d 1089, 1090 (9th Cir. 2003); see also Valdez 12 v. Allstate Ins. Co., 372 F.3d 1115, 1118 (9th Cir. 2004). 13 II. Analysis 14 Plaintiffs move to remand, arguing that the federal claims are not substantial and are 15 merely incidental to their state law claims. ECF No. 5 at 2. Plaintiffs additionally contend that 16 their federal claims are not independent of their state law claims. Id. at 4. Defendants argue in 17 response that the complaint contains numerous federal claims, and that this provides the court 18 with jurisdiction. ECF No. 9. 19 The court is satisfied that federal question jurisdiction exists. The complaint alleges 20 claims under the Fourth, Fifth, Eighth, and Fourteenth Amendments of the United States 21 Constitution; 42 U.S.C. § 1983, 42 U.S.C. §§ 1985, 1986, 14141; and 18 U.S.C. §§ 241, 242. 22 ECF No. 1 at 12. 23 Motion to Dismiss 24 I. Legal Standard 25 A complaint may be dismissed under that rule for “failure to state a claim upon which 26 relief may be granted.” Fed. R. Civ. P. 12(b)(6). To survive a motion to dismiss for failure to 27 state a claim, a plaintiff must allege “enough facts to state a claim to relief that is plausible on its 28 face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim has “facial plausibility 1 when the plaintiff pleads factual content that allows the court to draw the reasonable inference 2 that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 3 (2009) (citing Twombly, 550 U.S. at 556). The plausibility standard is not akin to a “probability 4 requirement,” but it requires more than a sheer possibility that a defendant has acted unlawfully. 5 Iqbal, 556 U.S. at 678. 6 For purposes of dismissal under Rule 12(b)(6), the court generally considers only 7 allegations contained in the pleadings, exhibits attached to the complaint, and matters properly 8 subject to judicial notice, and construes all well-pleaded material factual allegations in the light 9 most favorable to the nonmoving party. Chubb Custom Ins. Co. v. Space Sys./Loral, Inc., 710 10 F.3d 946, 956 (9th Cir. 2013); Akhtar v. Mesa, 698 F.3d 1202, 1212 (9th Cir. 2012). 11 Dismissal under Rule 12(b)(6) may be based on either: (1) lack of a cognizable legal 12 theory, or (2) insufficient facts under a cognizable legal theory. Chubb Custom Ins. Co., 710 F.3d 13 at 956. Dismissal also is appropriate if the complaint alleges a fact that necessarily defeats the 14 claim. Franklin v. Murphy, 745 F.2d 1221, 1228-29 (9th Cir. 1984). 15 II. Analysis 16 Plaintiffs allege that on June 8, 2023, Sacramento Police officers detained plaintiff Jones 17 for twenty to thirty minutes and searched his tent. ECF No. 1 at 8. The officers told Hall that 18 Jones was on probation, which allowed them to conduct the search. Id. In response to the search, 19 Hall called the Sacramento Probation Department, which stated that the probation department had 20 not sent the police to search Jones. Plaintiffs allege that at one point during the incident, the 21 officers yanked Jones to the ground with unreasonable force. Id. 22 On their form complaint, plaintiffs check the boxes for general negligence, intentional 23 tort, and include a reference to 42 U.S.C. § 1983. Id. at 7. Later in the complaint, plaintiffs list 24 violations of the Fourth, Fifth, Eighth, Fourteenth Amendments; sections Seven and Thirteen of 25 the California Constitution, 42 U.S.C. §§ 1983, 1985, 1986, 14141; and 18 U.S.C. §§ 241, 242. 26 Id. at 12. 27 Defendants argues that the complaint must be dismissed for four reasons. ECF No. 4-1 at 28 2. First, they argue that the complaint is vague and consists primarily of conclusory allegations. 1 Defendants next argue that Hall lacks standing because he was only a bystander and not involved 2 in the incident. Id. at 2-3. Third, they argue that plaintiffs’ negligence claims are improper 3 because defendants are public entities. Id. at 4. Finally, they argue that plaintiffs failed to 4 exhaust their administrative remedies under the California Tort Claims Act. 5 A. Halls’ Standing 6 Turning first to defendants’ standing argument, plaintiffs contend that Hall has standing to 7 sue because he was “directly affected by the defendant’s [sic] actions.” ECF No. 10-1 at 10. 8 They also argue that Hall can act as a legal representative for Jones. Id. at 3.

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

Related

United States v. Classic
313 U.S. 299 (Supreme Court, 1941)
United Mine Workers of America v. Gibbs
383 U.S. 715 (Supreme Court, 1966)
Alderman v. United States
394 U.S. 165 (Supreme Court, 1969)
Carnegie-Mellon University v. Cohill
484 U.S. 343 (Supreme Court, 1988)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Alvera M. Aldabe v. Charles D. Aldabe
616 F.2d 1089 (Ninth Circuit, 1980)
Harry Franklin v. Ms. Murphy and Hoyt Cupp
745 F.2d 1221 (Ninth Circuit, 1984)
Ronald Caldeira v. County of Kauai
866 F.2d 1175 (Ninth Circuit, 1989)
Matheson v. Progressive Specialty Insurance Company
319 F.3d 1089 (Ninth Circuit, 2003)
Michael Lacey v. Joseph Arpaio
693 F.3d 896 (Ninth Circuit, 2012)
Javiad Akhtar v. J. Mesa
698 F.3d 1202 (Ninth Circuit, 2012)
United States v. Mills
710 F.3d 5 (First Circuit, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
(PS) Jones v. City of Sacramento Board of Supervisors, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-jones-v-city-of-sacramento-board-of-supervisors-caed-2025.