Ronald Phillips v. County of Los Angeles

CourtDistrict Court, C.D. California
DecidedApril 1, 2020
Docket2:20-cv-01858
StatusUnknown

This text of Ronald Phillips v. County of Los Angeles (Ronald Phillips v. County of Los Angeles) 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
Ronald Phillips v. County of Los Angeles, (C.D. Cal. 2020).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 RONALD PHILLIPS, ) Case No. CV 20-1858-FMO (JPR) ) 11 Plaintiff, ) ORDER DISMISSING COMPLAINT WITH ) LEAVE TO AMEND 12 v. ) ) 13 COUNTY OF LOS ANGELES et ) al., ) 14 ) Defendants. ) 15 ) 16 On February 26, 2020, Plaintiff, a state inmate proceeding 17 pro se, filed a civil-rights action against Los Angeles County 18 and the Los Angeles County Public Defender in their official 19 capacity and Robert G. Noguchi, a deputy public defender, and 20 Does in their individual and official capacities, seeking 21 declaratory relief, compensatory and punitive damages, and costs. 22 (Compl. at 3, 6.)1 He was subsequently granted leave to proceed 23 in forma pauperis. 24 Plaintiff alleges “malpractice” and “negligence” by Noguchi 25 at his 2011 sentencing, resulting in a sentence of 32 months when 26 27 1 Because the Complaint is not consecutively paginated, the Court uses the pagination generated by its Case Management/ 28 Electronic Case Filing system. 1 1 it should have been 16. (Compl. at 5-8.) In 2017, the court 2 struck his prior juvenile misdemeanor adjudication and 3 resentenced him to 16 months. (Id. at 5, 11.) 4 After screening the Complaint under 28 U.S.C. §§ 1915(e)(2) 5 and 1915A, the Court finds that its allegations fail to state a 6 claim on which relief might be granted. Because some of the 7 claims might be cured by amendment, they are dismissed with leave 8 to amend. See Lopez v. Smith, 203 F.3d 1122, 1130-31 (9th Cir. 9 2000) (en banc). If Plaintiff desires to pursue any of his 10 claims, he is ORDERED to file a first amended complaint within 28 11 days of the date of this order, remedying the deficiencies 12 discussed below. 13 ALLEGATIONS 14 Public Defender Noguchi was appointed to represent Plaintiff 15 on or about January 20, 2011. (Compl. at 5.) He allegedly 16 “failed to exercise reasonable care and skill” by not asserting 17 during Plaintiff’s sentencing that because his prior juvenile 18 conviction was a misdemeanor, it should not have counted as a 19 prior-strike enhancement. (Id.) Plaintiff was sentenced to and 20 served 32 months. (Id.) 21 On June 28, 2017, his sentence was modified based on the 22 prosecutor’s motion to strike the prior-strike allegation. (Id. 23 at 12.) The court resentenced him to 16 months, with credit for 24 custody and good time. (Id. at 11.) 25 STANDARD OF REVIEW 26 A complaint may be dismissed as a matter of law for failure 27 to state a claim “where there is no cognizable legal theory or an 28 absence of sufficient facts alleged to support a cognizable legal 2 1 theory.” Shroyer v. New Cingular Wireless Servs., Inc., 622 F.3d 2 1035, 1041 (9th Cir. 2010) (as amended) (citation omitted); 3 accord O’Neal v. Price, 531 F.3d 1146, 1151 (9th Cir. 2008). In 4 considering whether a complaint states a claim, a court must 5 generally accept as true all the factual allegations in it. 6 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Hamilton v. Brown, 7 630 F.3d 889, 892-93 (9th Cir. 2011). The court need not accept 8 as true, however, “allegations that are merely conclusory, 9 unwarranted deductions of fact, or unreasonable inferences.” In 10 re Gilead Scis. Sec. Litig., 536 F.3d 1049, 1055 (9th Cir. 2008) 11 (citation omitted); see also Shelton v. Chorley, 487 F. App’x 12 388, 389 (9th Cir. 2012) (finding that district court properly 13 dismissed civil-rights claim when plaintiff’s “conclusory 14 allegations” did not support it). 15 Although a complaint need not include detailed factual 16 allegations, it “must contain sufficient factual matter, accepted 17 as true, to ‘state a claim to relief that is plausible on its 18 face.’” Iqbal, 556 U.S. at 678 (quoting Bell Atl. Corp. v. 19 Twombly, 550 U.S. 544, 570 (2007)); Yagman v. Garcetti, 852 F.3d 20 859, 863 (9th Cir. 2017). A claim is facially plausible when it 21 “allows the court to draw the reasonable inference that the 22 defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. 23 at 678. “A document filed pro se is ‘to be liberally construed,’ 24 and ‘a pro se complaint, however inartfully pleaded, must be held 25 to less stringent standards than formal pleadings drafted by 26 lawyers.’” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per 27 curiam) (citations omitted); Byrd v. Phx. Police Dep’t, 885 F.3d 28 639, 642 (9th Cir. 2018) (per curiam). 3 1 DISCUSSION 2 I. The Complaint Does Not State Any Official-Capacity Claim 3 Plaintiff sues Los Angeles County and the Los Angeles County 4 Public Defender in their official capacity and Noguchi in his 5 individual and official capacities. (Compl. at 3.) The Supreme 6 Court has held that an “official-capacity suit is, in all 7 respects other than name, to be treated as a suit against the 8 entity.” Kentucky v. Graham, 473 U.S. 159, 166 (1985); see also 9 Brandon v. Holt, 469 U.S. 464, 471-72 (1985). Such a suit “is 10 not a suit against the official personally, for the real party in 11 interest is the entity.” Graham, 473 U.S. at 166 (emphasis in 12 original). Thus, Plaintiff’s claims against Noguchi in his 13 official capacity are redundant to his claims against the LACPD. 14 Municipalities and local-government entities are considered 15 “persons” under 42 U.S.C. § 1983 and therefore may be liable for 16 causing a constitutional deprivation. See Monell v. Dep’t of 17 Soc. Servs., 436 U.S. 658, 690-91, 694 (1978); see also Long v. 18 Cnty. of L.A., 442 F.3d 1178, 1185 (9th Cir. 2006). Because no 19 respondeat superior liability exists under § 1983, a municipality 20 is liable only for injuries that arise from an official policy or 21 longstanding custom. Monell, 436 U.S. at 694; City of Canton v. 22 Harris, 489 U.S. 378, 385-87 (1989). A plaintiff must show “that 23 a [municipal] employee committed the alleged constitutional 24 violation pursuant to a formal governmental policy or a 25 ‘longstanding practice or custom which constitutes the standard 26 operating procedure of the local governmental entity.’” Gillette 27 v. Delmore, 979 F.2d 1342, 1346 (9th Cir. 1992) (per curiam) 28 (citation omitted). 4 1 A plaintiff may also establish municipal liability by 2 demonstrating that the alleged constitutional violation was 3 caused by a failure to train municipal employees adequately. See 4 Harris, 489 U.S. at 388. A plaintiff claiming failure to train 5 must allege facts demonstrating the following: 6 (1) he was deprived of a constitutional right, (2) the 7 [County] had a training policy that amounts to deliberate 8 indifference to the constitutional rights of the persons 9 with whom its [employees] are likely to come into 10 contact, and (3) his constitutional injury would have 11 been avoided had the [County] properly trained those 12 [employees]. 13 Blankenhorn v. City of Orange, 485 F.3d 463, 484 (9th Cir. 2007) 14 (citations and alterations omitted); see also Lee v.

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313 U.S. 299 (Supreme Court, 1941)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
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454 U.S. 312 (Supreme Court, 1981)
Briscoe v. LaHue
460 U.S. 325 (Supreme Court, 1983)
Brandon v. Holt
469 U.S. 464 (Supreme Court, 1985)
Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Bartlett v. Strickland
556 U.S. 1 (Supreme Court, 2009)
United States v. Bailey
622 F.3d 1 (D.C. Circuit, 2010)
Hamilton v. Brown
630 F.3d 889 (Ninth Circuit, 2011)
Michael Henry Ferdik v. Joe Bonzelet, Sheriff
963 F.2d 1258 (Ninth Circuit, 1992)
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Lee v. City Of Los Angeles
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Bluebook (online)
Ronald Phillips v. County of Los Angeles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-phillips-v-county-of-los-angeles-cacd-2020.