Robert Hart v. Edgardo Sandoval, an individual, and County of Tulare, a public entity

CourtDistrict Court, E.D. California
DecidedSeptember 18, 2025
Docket1:24-cv-00071
StatusUnknown

This text of Robert Hart v. Edgardo Sandoval, an individual, and County of Tulare, a public entity (Robert Hart v. Edgardo Sandoval, an individual, and County of Tulare, a public entity) 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
Robert Hart v. Edgardo Sandoval, an individual, and County of Tulare, a public entity, (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 ROBERT HART, Case No. 1:24-cv-00071-HBK 12 Plaintiff, ORDER DENYING DEFENDANTS’ REQUEST FOR JUDICIAL NOTICE 13 v. (Doc. No. 24-6) 14 EDGARDO SANDOVAL, an individual, and COUNTY OF TULARE, a public ORDER GRANTING DEFENDANTS’ 15 entity, MOTION FOR SUMMARY JUDGMENT1 16 Defendants. (Doc. No. 24) 17 18 19 Defendants Edgardo Sandoval (“Sandoval”) and the County of Tulare (“County”) filed a 20 Motion for Summary Judgment on June 23, 2025. (Doc. No. 24, “Motion”). Defendants seek 21 summary judgment against Plaintiff Robert Hart (“Plaintiff”) on all claims. (Id.). Plaintiff filed 22 an Opposition (Doc. No. 25), and Defendants filed a Reply (Doc. No. 32). The Court finds the 23 matter suitable for decision without oral arguments. (Doc. No. 37). Finding no material facts in 24 dispute, the Court grants Defendants’ Motion for Summary Judgment. 25 //// 26

27 11 Both parties have consented to the jurisdiction of a magistrate judge in accordance with 28 U.S.C. §636(c)(1). (Doc. No. 12). 28 1 I. BACKGROUND

2 A. Procedural History

3 On January 17, 2024, Plaintiff initiated this action by filing a civil rights complaint against

4 Defendants Edgardo Sandoval and County of Tulare. (Doc. No. 1, “Complaint”). Therein,

5 Plaintiff alleges Defendants arrested him for domestic violence without an arrest warrant and

6 without probable cause on January 18, 2022. (Id. at 3-5). The Complaint vaguely alleges that

7 “the violations of Plaintiff’s constitutional rights complained of herein were caused by the

8 customs, policies, and/or practices of authorized policymakers of [the County’s sheriff’s

9 department], which encouraged, authorized, directed, condoned, and/or ratified the

10 unconstitutional and unlawful conduct complained of herein.” (Id. at 3). The Complaint contains

11 two causes of action pursuant to 42 U.S.C. § 1983: (1) False Arrest and Imprisonment – Fourth

12 and Fourteenth Amendments; and (2) Equal Protection Clause. (Id. at 5-6). On May 6, 2024,

13 Defendants filed their Answer. (Doc. No. 8). On June 23, 2025, following discovery in this

14 matter, Defendants filed the i nstant Motion for Summary Judgment on all Plaintiff’s claims. 15 (Doc. No. 24). Plaintiff filed an Opposition on July 7, 2025.2 (Doc. No. 25). Defendants filed 16 their Reply on July 16, 2025. (Doc. No. 32). 17 B. Arguments and Record Before the Court 18 In support of their Motion, Defendants submit: a Memorandum of Points and Authorities 19 (Doc. No. 24-1); a Statement of Undisputed Material Facts (Doc. No. 24-2); Defendant 20 Sandoval’s Declaration, with various exhibits, including multiple incident and crime reports from 21 Defendants’ encounters with Plaintiff and his wife, a copy of an emergency protective order 22 (“EPO”) against Plaintiff, photos of Plaintiff’s wife, Elizabeth “Lily” Hart, and Plaintiff’s 23 discovery responses (see Doc. No. 24-3, Exhibits A-O); and various body camera footage from 24 responding officers (see Doc. No. 24-4, Exhibits B-K); and Defendants Request for Judicial 25 Notice (Doc. No. 24-6). Defendants argue that because Sandoval had probable cause to believe 26 2 Plaintiff’s opposition was initially filed as a combined opposition and cross motion for partial 27 summary judgment. (See Doc. No. 25 at 6; Doc. No. 29). Plaintiff subsequently filed a notice of withdrawal of his cross-motion based on Defendants’ objection to the filing of a cross motion 28 after the deadline set by the Scheduling Order. (Doc. No. 31). 1 Plaintiff committed acts of domestic violence against his wife, Plaintiff’s false arrest claim

2 necessarily fails. (Doc. 24-1 at 11). Defendants point to reports from both Plaintiff’s wife, Lily,

3 and her friend Vicki that Plaintiff had harmed Lily a few weeks earlier and again the morning of

4 Plaintiff’s arrest; reports that Lily and Vicki had pictures of Lily’s past injuries; Sandoval’s

5 confirmation that there were unsecured firearms in the home; and the issuance of the EPO against

6 Plaintiff for Lily as supporting probable cause for Plaintiff’s arrest. (Id. at 13-14). Alternatively,

7 Defendants argue Sandoval is entitled to qualified immunity. (Id. at 14-15 (citing Rodis v. City

8 and Cnty. of San Francisco, 558 F.3d 964, 970-71 (9th Cir. 2009))).

9 As to Plaintiff’s Equal Protection claim, Defendants argue Plaintiff’s Complaint fails to

10 provide any factual allegations describing how his rights were violated, and to the extent

11 Plaintiff’s discovery responses indicate his claim is based on allegedly different treatment

12 between himself and Lily, such a claim fails because Plaintiff’s January 18, 2022 arrest and an

13 earlier arrest on July 21, 2021 were both supported by probable cause. (Id. at 17-19). Defendants

14 argue a false arrest claim agai nst the County is improper because “a local government may not be 15 sued under Section 1983 for an injury inflicted solely by its employees or agents” and because 16 there is a lack of a constitutional violation or evidence that such was the result of a policy, 17 custom, or practice of the County, Plaintiff cannot establish liability pursuant to Monell v. 18 Department of Social Services, 456 U.S. 658, 694 (1978). (Id. at 10-11, 20-22). 19 Plaintiff’s Opposition includes a Memorandum of Points and Authorities (Doc. No. 25) 20 and is supported by a Statement of Undisputed Facts and Additional Material Facts (Doc. No. 21 26); Sandoval’s deposition transcript and Plaintiff’s declaration (see Doc. No. 27); and body 22 camera footage from two additional officers (see Doc. No. 30). In arguing that probable cause for 23 his arrest did not exist, Plaintiff attacks Lily’s credibility and asserts that no reasonable officer 24 would have found her reports to be “reasonably trustworthy.” (Doc. No. 25 at 18). Plaintiff 25 argues that “officers failed to take independent action to attempt to corroborate the statements 26 before they arrested Robert” such that the arrest was not supported by probable cause. (Id. at 18- 27 19). Additionally, Plaintiff argues that because the arrest occurred in the curtilage of his home, it 28 was presumptively unreasonable. (Id. at 19-23). Plaintiff argues Defendants cannot rebut the 1 presumption of unreasonableness because Lily did not consent to a search of the home and there

2 were no emergency or exigent circumstances to justify his arrest given that Plaintiff was

3 immediately detained as soon as he returned to the property and could not access any contraband

4 in the home. (Id. at 24-25). As to the Equal Protection claim, Plaintiff argues Defendants failed

5 to satisfy their initial burden of presenting evidence negating the claim or demonstrating

6 Plaintiff’s inability to produce such evidence. (Id. at 29).

7 Defendants’ Reply is accompanied by their reply to Plaintiff’s opposition to their

8 statement of material facts and Defendant’s opposition to Plaintiff’s additional material facts.

9 (Doc. No. 32-1). In their Reply, Defendants’ argue summary judgment is proper because “the

10 undisputed facts show that at the time Deputy Sandoval arrested Plaintiff, he reasonably believed

11 that Plaintiff had committed a crime of domestic violence when he pushed his wife down during

12 an earlier altercation and [Lily] Hart consented to the [sheriff’s department’s] presence to

13 investigate Plaintiff’s alleged acts of domestic violence.” (Doc. No. 32 at 2). Defendants argue

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Robert Hart v. Edgardo Sandoval, an individual, and County of Tulare, a public entity, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-hart-v-edgardo-sandoval-an-individual-and-county-of-tulare-a-caed-2025.