VW CREDIT LEASING LTD v. The City of San Mateo

CourtDistrict Court, N.D. California
DecidedNovember 7, 2023
Docket4:23-cv-02884
StatusUnknown

This text of VW CREDIT LEASING LTD v. The City of San Mateo (VW CREDIT LEASING LTD v. The City of San Mateo) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
VW CREDIT LEASING LTD v. The City of San Mateo, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 VW CREDIT LEASING LTD, Case No. 23-cv-02884-DMR

8 Plaintiff, ORDER ON CITY OF SAN MATEO'S 9 v. MOTION TO DISMISS

10 THE CITY OF SAN MATEO, et al., Re: Dkt. No. 18 11 Defendants.

12 In this action, Plaintiff VW Credit Leasing LTD (“VWCL”) challenges Defendant City of 13 San Mateo’s (“San Mateo”) alleged practice of turning over control of seized vehicles to private 14 tow companies, including Defendant Red Line Towing (“Red Line”), without providing due 15 process. San Mateo now moves to dismiss the claims asserted against it pursuant to Federal Rule 16 of Civil Procedure 12(b)(6). [Docket No. 18.] This matter is suitable for resolution without a 17 hearing. Civ. L.R. 7-1(b). For the following reasons, the motion is denied. 18 I. BACKGROUND 19 VWCL makes the following allegations in the first amended complaint (“FAC”), all of 20 which are taken as true for purposes of the motion to dismiss.1 VWCL is the titled owner of a 21 2020 Volkswagen bearing VIN 3VWCB7BUXLM068420 (the “vehicle”). It was a party to a 22 vehicle lease agreement with Anna Paley. [Docket No. 9 (FAC) ¶¶ 7, 10, 11, Exs. A, B.] Starting 23 in May 2021, Paley failed to make her monthly car payments. As a result, VWCL became entitled 24 to immediate possession of the vehicle under the terms of the lease agreement. FAC ¶¶ 12, 13. 25 On September 15, 2021, San Mateo took custody of the vehicle and instructed Red Line to 26 1 When reviewing a motion to dismiss for failure to state a claim, the court must “accept as true all 27 of the factual allegations contained in the complaint.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) 1 tow it from the roadway, store it, and “not to release it without prior approval from San Mateo.” 2 Id. at ¶ 16. VWCL alleges that Defendants’ seizure of the vehicle was without a warrant and “was 3 unaccompanied by any legitimate exception to the warrant requirement.” Id. at ¶¶ 49, 50. It 4 further alleges that “to the extent the initial seizure was accompanied by any arguably legitimate 5 exception to the warrant requirement, it was carried out in an unreasonable manner of execution 6 insofar as the seizure exceeded the scope necessary to complete any legitimate task associated 7 with the purported warrant exception for which the vehicle was seized.” Id. at ¶ 50. 8 VWCL alleges that it first discovered that the vehicle had been impounded on November 9 4, 2021, when it received a “Notice of Stored Vehicle” advising it of charges for storage, towing, 10 and a title search. Id. at ¶ 18, Ex. C. The Notice of Stored Vehicle lists total charges of $1,510 11 and states, “you are the last Legal Owner of record for this vehicle. Per the requirements of the 12 California Vehicle Code and Civil Code, you are hereby notified that the above described vehicle 13 has been placed in storage. Please contact us at the address shown above and pay the charges if 14 you intend to reclaim this vehicle.” Id. 15 When VWCL contacted Red Line to recover the vehicle, Red Line demanded payment of 16 $4,400 in towing and storage charges before it would release the vehicle to VWCL and claimed a 17 lien on the vehicle for the outstanding charges. FAC ¶¶ 19-21. Red Line claimed that it was not 18 permitted to release the vehicle “unless or until San Mateo authorized Red Line to do so.” Id. at ¶ 19 22. VWCL did not pay the fees that Red Line demanded. It alleges upon information and belief 20 that Red Line sold the vehicle and kept the sale proceeds. Id. at ¶¶ 24, 25. San Mateo did not 21 compensate VWCL for the extinguishment of its property rights in the vehicle. Id. at ¶ 72. 22 Further, “[n]either San Mateo nor Red Line provided VWCL an opportunity to be heard in relation 23 to either Defendants’ actions in relation to the Vehicle in any venue at any time.” Id. at ¶ 59. 24 VWCL alleges that San Mateo benefited from Red Line’s detention of the vehicle “in that 25 San Mateo obtained Red Line’s impound storage services, as well as Red Line’s towing services 26 to clear the roadway, with no payment (or reduced payment) of money from San Mateo to Red 27 Line. Id. at ¶ 26. VWCL further alleges that “[t]o the extent San Mateo or Red Line seek to rely 1 unconstitutional as applied to the circumstances.” Id. at ¶ 23. 2 VWCL alleges that Defendants’ regular policy and custom is to not obtain a warrant for 3 their actions, including initially seizing a vehicle; turning over possession of a vehicle to Red 4 Line; the decision to continue to detain vehicles after the initial reason for the seizure has passed; 5 the decision by Red Line to assert a possessory lien in vehicles and then terminate all property 6 interests in vehicles; and the eventual sale of vehicles. Id. at ¶ 39. It alleges that even if the initial 7 warrantless seizure of vehicles is pursuant to an valid exception to the Fourth Amendment’s 8 warrant requirement, Defendants’ “subsequent actions render the seizures unreasonable in their 9 manner of execution[.]” Id. at ¶ 40. Additionally, VWCL alleges that Defendants’ regular policy 10 and custom is to not provide any form of constitutionally adequate notice or any hearing 11 whatsoever with respect to the foregoing actions. Id. at ¶ 41. According to VWCL, San Mateo 12 benefits from these actions “by avoiding the costs of preserving the seized vehicles and towing 13 services by permitting the towing company to keep the vehicle as compensation,” while Red Line 14 “benefits by using its control over the vehicle (created under mantle of authority from San Mateo) 15 to profit by conditioning release of the vehicle upon payment of money . . . or by selling the 16 vehicle in the absence of payment.” Id. at ¶ 2. 17 VWCL asserts the following claims for relief: 1) a 42 U.S.C. § 1983 claim for 18 unreasonable seizure in violation of the Fourth Amendment against both Defendants; 2) a section 19 1983 claim for deprivation of property without due process in violation of the Fourteenth 20 Amendment against both Defendants; 3) a section 1983 claim for taking of property without just 21 compensation in violation of the Fifth Amendment against San Mateo; 4) declaratory relief against 22 both Defendants; 5) replevin against Red Line; 6) conversion against Red Line; and 7) tortious 23 interference with contractual relations and/or prospective economic advantage against Red Line. 24 San Mateo now moves to dismiss all of VWCL’s claims against it (claims one through 25 four). 26 II. LEGAL STANDARD 27 A motion to dismiss under Rule 12(b)(6) tests the legal sufficiency of the claims alleged in 1 When reviewing a motion to dismiss for failure to state a claim, the court must “accept as true all 2 of the factual allegations contained in the complaint,” Erickson, 551 U.S. at 94, and may dismiss a 3 claim “only where there is no cognizable legal theory” or there is an absence of “sufficient factual 4 matter to state a facially plausible claim to relief.” Shroyer v. New Cingular Wireless Servs., Inc., 5 622 F.3d 1035, 1041 (9th Cir. 2010) (quotation marks omitted) (quoting Navarro v. Block, 250 6 F.3d 729, 732 (9th Cir. 2001)) (citing Ashcroft v. Iqbal, 556 U.S. 662, 677-78 (2009)). A claim 7 has facial plausibility when a plaintiff “pleads factual content that allows the court to draw the 8 reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 9 678 (citation omitted).

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VW CREDIT LEASING LTD v. The City of San Mateo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vw-credit-leasing-ltd-v-the-city-of-san-mateo-cand-2023.