Sandy A. Eulitt v. City of San Diego, et al.

CourtDistrict Court, S.D. California
DecidedMarch 25, 2026
Docket3:18-cv-02721
StatusUnknown

This text of Sandy A. Eulitt v. City of San Diego, et al. (Sandy A. Eulitt v. City of San Diego, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sandy A. Eulitt v. City of San Diego, et al., (S.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 SANDY A. EULITT, Case No.: 18-cv-02721-RBM-DEB

12 Plaintiff, ORDER: 13 v. (1) GRANTING THE CITY’S 14 CITY OF SAN DIEGO, et al. MOTION TO STRIKE 15 Defendants. (2) GRANTING THE CITY’S 16 MOTION TO DISMISS 17 18 (3) DENYING PLAINTIFF’S MOTION TO STAY AND FOR 19 APPOINTMENT OF 20 COUNSEL

21 (4) DENYING PLAINTIFF’S 22 MOTION FOR CLASS 23 CERTIFICATION

24 [Docs. 100, 101, 102, 103] 25 26 27 Defendant City of San Diego (“Defendant” or “the City”) has filed two motions: (1) 28 a Motion to Strike Plaintiff’s Fourth Amended Complaint (“4AC”); and (2) a Motion to 1 Dismiss Plaintiff’s 4AC (Docs. 100, 101). Plaintiff Sandy A. Eulitt (“Plaintiff”), 2 proceeding pro se, did not oppose either of these motions but instead filed “conditional 3 oppositions” arguing the Court should not consider the City’s motions until her motions 4 for class certification and appointment of counsel, filed after the City’s motions, were ruled 5 on. (Docs. 104–105.) The City’s reply briefs note Plaintiff’s “conditional oppositions” do 6 not comply with the requirements for an opposition to a motion and argue Plaintiff has 7 waived opposition. (Doc. 107 at 2–3; Doc. 108 at 2–3.1) 8 Plaintiff has filed three motions: (1) Motion to Stay Proceedings (Doc. 102 at 1–5); 9 (2) Motion for Appointment of Counsel (Doc. 102-2–102-5);2 and (2) Motion to Certify 10 Class. (Doc. 103, 110 (supplement to motion improperly filed without leave of court a 11 week after motion filing).) The City has filed oppositions to each of Plaintiff’s motions. 12 (Docs. 106, 111.) Plaintiff has filed reply briefs. (Docs. 109–110, 112.) 13 The Court finds the matter suitable for determination on the papers and without oral 14 argument pursuant to Civil Local Rule 7.1(d)(1). For the reasons set forth below, the 15 Motion to Strike (Doc. 100) and Motion to Dismiss (Doc. 101) are GRANTED. The 16 Motion to Certify Class, Motion for Appointment of Counsel, and Motion to Stay are 17 DENIED. 18 I. BACKGROUND 19 A. Fourth Amended Complaint 20 As discussed further below (see infra II.B), Plaintiff’s 4AC fails to comply with 21 Federal Rule of Civil Procedure 8’s requirement of a “short and plain statement of the claim 22 showing the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Despite dismissal on this 23 basis as well as the lack of oppositions to the City’s motions (see infra II.A), the Court 24 25 26 1 The Court cites the paragraph numbers of the 4AC and the CM/ECF electronic pagination 27 for all other cites to the record unless otherwise noted. 2 The Motion to Appoint Counsel was filed and docketed with the Motion to Stay. (Doc. 28 1 briefly summarizes some of the allegations of Plaintiff’s lengthy 4AC for purposes of 2 addressing the motions before the Court. 3 In the 4AC, Plaintiff alleges that “the City has unlawfully enforced a repealed 1942 4 ordinance—San Diego Ordinance 2584” (“O-2584”) that Plaintiff refers to as the “six- 5 month rule.” (Id. ¶¶ 1–2, 118–122.)3 Plaintiff asserts that “[t]his policy, enforced at 6 Coastal Trailer Villa Park [(“CTV”)] until its closure in 2019 and at Morena Mobile Village 7 [(“MMV”)]), has forced vulnerable residents into repeated dislocation and instability, 8 inflicting measurable financial, physical, and emotional harm.” (Id. ¶ 2.) Plaintiff alleges 9 the six-month rule “is a discriminatory, outdated policy that disproportionately impacts 10 people with disabilities and older adults—many of whom reside in older RVs excluded by 11 vehicle age restrictions at other parks such as Santa Fe RV Park.” (Id. ¶ 3.) Plaintiff claims 12 “the City has persisted in enforcing an invalid ordinance—knowingly or with deliberate 13 indifference—placing Plaintiffs’ health, safety, and housing security at risk.” (Id. ¶ 5.) 14 “Plaintiff seeks injunctive and declaratory relief, along with damages, to end this 15 unconstitutional and unlawful enforcement and to protect the rights of a vulnerable class 16 pushed into the margins of San Diego’s housing system.” (Id. ¶ 6.) 17 Although Plaintiff’s 4AC includes many allegations from years before, this litigation 18 seems to originate from an October 31, 2016 “7-Day Notice to Comply” from CTV to 19 Plaintiff that, in addition to “citing multiple alleged violations,” included reference to 20 Plaintiff “exceeding the six-month maximum occupancy period under Ordinance 2584.” 21 (Id. ¶¶ 68, 123.) On June 29, 2018, “CTV filed an Unlawful Detainer action against 22 23 24 3 The Court notes that the repeal of the ordinance was only raised in briefing before the 25 Ninth Circuit Court of Appeals. Eulitt v. City of San Diego, No. 21-55920, 2024 WL 2350642, at *1 (9th Cir. May 23, 2024) (“For the first time on appeal, the City contends 26 that it repealed the ordinance originating the Six-Month Rule in 1954, decades before the 27 events alleged in [Plaintiff’s] complaint. Because the City’s belated contention dramatically altered the nature of the issues on appeal, we vacate the district court’s order 28 1 Plaintiff” with “supporting documents in that case explicitly cit[ing] Ordinance 2584 as the 2 legal basis for eviction.” (Id. ¶ 72.) Plaintiff’s 4AC includes a section that details her 3 locations, moves as a result of the six-month rule, and her medical history from 2009 4 through 2021. (Id. ¶¶ 230–278.) 5 Plaintiff “is a 62-year-old former resident of San Diego [that] suffers from a serious 6 and multifaceted spinal condition, compounded by anxiety, depression, and gastrointestinal 7 issues” that she blames on the “repeated forced relocations and legal threats surrounding 8 enforcement of the ‘six-month rule.’” (Id. ¶ 11.) She alleges that, despite hiring movers, 9 “she was repeatedly forced to perform physically demanding tasks during RV 10 relocations—tasks that inflicted cumulative and sometimes catastrophic trauma to her 11 spine. (Id. ¶ 12.) She relies on a “fixed disability income” and asserts she “is a qualified 12 individual with disabilities under the [ADA]” and § 504. (Id. ¶¶ 11, 13.) 13 Plaintiff asserts that, based on redevelopment planning over 15 years, the City should 14 have known that many of the individuals required to relocate because of the six-month rule 15 were elderly or disabled and this was a “reckless and discriminatory policy under both state 16 and federal law.” (Id. ¶¶ 74, 77.) Plaintiff points to San Diego’s housing market being 17 “chronically unaffordable for low income and disabled individuals” (id. ¶ 78) and a known 18 shortfall of affordable homes, but also alleges generally that the lack of affordable housing 19 “disproportionately affects individuals with disabilities and seniors on fixed incomes,” as 20 well as many residents of CTV. (Id. at ¶¶ 78–79, 86–94, 104–111.) Plaintiff also asserts 21 that many individuals required to relocate as a result of enforcement of the six-month rule 22 faced difficulties in parking their RVs on city streets because of municipal codes limiting 23 where oversized vehicles can be parked and for how long, and that they could not relocate 24 outside San Diego because the parks in neighboring communities like Lakeside, Santee, 25 La Mesa, El Cajon, and Chula Vista, charge higher rents. (Id. ¶¶ 78–85, 126, 133.) 26 Plaintiff cites numerous articles about the hardships in moving for seniors and the disabled 27 (id. ¶¶ 95–98) and asserts “these findings … confirm that [the City’s] actions—repeatedly 28 forcing elderly and disabled RV park residents to relocate—caused foreseeable, 1 disproportionate, and serious harm” (id. ¶ 99).

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Bluebook (online)
Sandy A. Eulitt v. City of San Diego, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/sandy-a-eulitt-v-city-of-san-diego-et-al-casd-2026.