Roberto Jose Cota v. Santa Ana Police Department

CourtDistrict Court, C.D. California
DecidedNovember 23, 2021
Docket8:21-cv-01774
StatusUnknown

This text of Roberto Jose Cota v. Santa Ana Police Department (Roberto Jose Cota v. Santa Ana Police Department) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roberto Jose Cota v. Santa Ana Police Department, (C.D. Cal. 2021).

Opinion

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8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 SOUTHERN DIVISION 11 ROBERTO JOSE COTA, ) Case No. 8:21-CV-01774-MWF-JDE ) 12 Plaintiff, ) ) ORDER TO SHOW CAUSE WHY ) 13 v. ) CASE SHOULD NOT BE ) DISMISSED 14 SANTA ANA POLICE ) DEPARTMENT, et al., ) 15 Defendants. ) )

16 )

17 I. 18 INTRODUCTION 19 On October 25, 2021, Plaintiff Roberto Jose Cota (“Plaintiff”), a pretrial 20 detainee at Orange County Jail, proceeding pro se and seeking to proceed in 21 forma pauperis (“IFP”), filed a Complaint under 42 U.S.C. § 1983 (“Section 22 1983” or “§ 1983”) against Defendants Santa Ana Police Department 23 (“SAPD”), David Valentin, Gallardo, John Doe, and Gus Morroyoqui. Dkt. 1 24 (“Complaint”); Dkt. 2 (“IFP Request”). 25 Because Plaintiff, a detainee, seeks redress in the Complaint against 26 government officials and entities, and because Plaintiff seeks leave to proceed 27 IFP, under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A, the Court must, as soon as 28 practicable, review and dismiss the Complaint if it is frivolous or malicious, 1 fails to state a claim on which relief may be granted, or seeks monetary 2 damages from a defendant immune from such relief. 3 II. 4 SUMMARY OF PLAINTIFF’S ALLEGATIONS 5 On May 28, 2018, Plaintiff, a tow-truck operator, was in a parking lot in 6 Santa Ana, California when he heard what he believed to be gun shots coming 7 from a nearby parking lot. Complaint ¶¶ 11-13. Plaintiff drove to the nearby 8 parking lot and observed a group of bystanders surrounding an injured victim. 9 Id. ¶14. Plaintiff then began rendering aid to the victim until the Fire 10 Department arrived a few minutes later, at which point Plaintiff returned to his 11 parked vehicle. Id. ¶¶ 15-16. Shortly thereafter, officers from the SAPD arrived 12 at the parking lot and began conducting witness interviews. Id. ¶ 17. Plaintiff 13 approached Defendant Gallardo, an SAPD officer, and notified him that 14 Plaintiff’s vehicle had a dash camera that may have captured relevant footage. 15 Id. ¶ 18. Defendant Gallardo indicated to Plaintiff he would be interested in 16 interviewing Plaintiff, and asked Plaintiff to “wait for a few minutes,” which 17 Plaintiff obliged. Id. Defendant Gallardo briefly interviewed Plaintiff, and at 18 10:15 p.m., before completing the interview, instructed Plaintiff to move his 19 vehicle and to turn it off as to not waste gas. Id. ¶ 20. Plaintiff alleges he felt 20 “compelled” to comply with Defendant Gallardo’s orders and accordingly 21 moved his vehicle and believed he “couldn’t leave.” Id. ¶ 21. Plaintiff claims 22 Defendant Gallardo never told Plaintiff he was permitted to leave and never 23 provided Plaintiff with an explanation for his detention. Id. ¶ 22. 24 Later that night, Defendant John Doe, an SADP crime scene 25 investigator, approached Plaintiff and requested to inspect Plaintiff’s dash 26 camera, which Plaintiff obliged. Id. ¶ 25. Defendant Doe also requested to 27 review the footage stored on Plaintiff’s dash camera, but Plaintiff denied the 28 request. Id. ¶ 25. Upon returning the dash camera to Plaintiff, Defendant Doe 1 “ordered” Plaintiff to call Plaintiff’s boss and notify him that the police officers 2 would not “let [Plaintiff] go until the detective is done interviewing everyone.” 3 Id. ¶ 26. Plaintiff then sat in his vehicle and waited “for a few hours” until 4 Defendant Morroyoqui, an SADP detective, arrived at the parking lot and 5 began interviewing the present witnesses, including Plaintiff. Id. ¶ 27. 6 Following his interview with Plaintiff, Defendant Morroyoqui requested to 7 examine Plaintiff’s dash camera, but Plaintiff informed Defendant Morroyoqui 8 he was unable to locate the dash camera. Id. ¶ 28. At 2:12 a.m. the following 9 morning, Plaintiff was “allowed to leave” the parking lot and went home. Id. 10 Plaintiff alleges Defendants violated his Fourth Amendment right to be 11 free from unreasonable searches and seizures by detaining him for over three 12 hours without probable cause or reasonable suspicion of any wrongdoing. Id. 13 ¶¶ 29, 53-54. Plaintiff generally claims that Defendant David Valentin “allows 14 his officers and detectives to engage in unlawful searches and seizures,” and 15 further alleges Defendants Gallardo, Morroyoqui, and Doe acted wantonly, 16 maliciously, and willfully. Id. ¶¶ 51-52. Plaintiff seeks :(1) a declaratory 17 judgment that Defendants violated his Fourth Amendment rights; (2) an 18 injunction enjoining Defendants from engaging in unlawful detentions of 19 Santa Ana residents; and (3) nominal and punitive damages. Id. ¶ 55. 20 In Count 1, Plaintiff alleges Defendants violated his Fourth Amendment 21 rights by seizing him without probable cause or reasonable suspicion. Id. ¶ 53. 22 In Count 2, Plaintiff alleges Defendants violated his Fourth Amendment rights 23 by prolonging his unlawful detention in an effort to gain access to Plaintiff’s 24 dash camera without informing Plaintiff that he had a right to leave. Id. ¶ 54. 25 III. 26 STANDARD OF REVIEW 27 As noted, under 28 U.S.C. §§ 1915(e)(2) and 1915A, a district court must 28 dismiss a complaint in this circumstance if it fails to state a claim on which 1 relief may be granted. See Calhoun v. Stahl, 254 F.3d 845, 845 (9th Cir. 2001) 2 (per curiam) (finding that the provisions of 28 U.S.C. § 1915(e)(2)(B) are not 3 limited to prisoners but includes pretrial detainees). 4 A complaint may be dismissed for failure to state a claim due to a lack of 5 a cognizable legal theory or insufficient facts alleged under a cognizable legal 6 theory. Balistreri v. Pacifica Police Dep't, 901 F.2d 696, 699 (9th Cir. 1990). 7 When reviewing a complaint to determine whether it states a viable 8 claim, the Court applies the same standard as it would when evaluating a 9 motion to dismiss under Federal Rule of Civil Procedure (“Rule”) 12(b)(6). See 10 Rosati v. Igbinoso, 791 F.3d 1037, 1039 (9th Cir. 2015) (citation omitted). 11 Rule 12(b)(6), in turn, is read in conjunction with Rule 8(a) . Zixiang Li v. 12 Kerry, 710 F.3d 995, 998 (9th Cir. 2013). Under Rule 8, a complaint must 13 contain a “short and plain statement of the claim showing that the pleader is 14 entitled to relief.” Rule 8(a)(2). While Rule 8 does not require detailed factual 15 allegations, at a minimum a complaint must allege enough specific facts to 16 provide both “fair notice” of the particular claim being asserted and “the 17 grounds upon which [that claim] rests.” Bell Atlantic Corp. v. Twombly, 550 18 U.S. 544, 555 (2007) (citation and quotation marks omitted); see also Ashcroft 19 v. Iqbal, 556 U.S. 662, 678 (2009) (observing that Rule 8 pleading standard 20 “demands more than an unadorned, the-defendant-unlawfully-harmed-me 21 accusation”) (citing Twombly, 550 U.S. at 555).

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Roberto Jose Cota v. Santa Ana Police Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roberto-jose-cota-v-santa-ana-police-department-cacd-2021.