Wayne McKay v. Yuba County, et al.

District Court, E.D. California·Decided December 3, 2025·No. 2:25-cv-02024·Unknown

Opinion

WAYNE MCKAY, Case No. 2:25-cv-02024-DAD-JDP (PS) Plaintiff, v. ORDER YUBA COUNTY, et al., Defendants. Plaintiff, proceeding pro se, brings this case against Yuba County, Yuba County Sheriff Wendell Anderson, and two sheriff’s deputies, Keith Gelber and Brian Clegg. He alleges that these defendants violated his constitutional rights when, in July 2023, they ordered him to leave real property whose ownership was disputed between plaintiff and the “prior owner.” ECF No. 6 at 6-11. Defendants have moved to dismiss most of plaintiff’s claims, ECF No. 9, save for his allegation that their actions amounted to an unlawful seizure of the real property. Id. at 9-1 at 3 n.1. After review of the pleadings, including plaintiff’s sur-reply, ECF No. 18-1, which I have reviewed out of an abundance of caution, I find that defendants’ motion should be granted. I will dismiss the claims implicated therein with leave to amend. Additionally, I will deny plaintiff’s motion to amend or quash summons, ECF No. 12, as unnecessary. Motion to Dismiss I. Legal Standards A complaint may be dismissed under that rule for “failure to state a claim upon which relief may be granted.” Fed. R. Civ. P. 12(b)(6). To survive a motion to dismiss for failure to state a claim, a plaintiff must allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim has “facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 556). The plausibility standard is not akin to a “probability requirement,” but it requires more than a sheer possibility that a defendant has acted unlawfully. Iqbal, 556 U.S. at 678. For purposes of dismissal under Rule 12(b)(6), the court generally considers only allegations contained in the pleadings, exhibits attached to the complaint, and matters properly subject to judicial notice, and construes all well-pleaded material factual allegations in the light most favorable to the nonmoving party. Chubb Custom Ins. Co. v. Space Sys./Loral, Inc., 710 F.3d 946, 956 (9th Cir. 2013); Akhtar v. Mesa, 698 F.3d 1202, 1212 (9th Cir. 2012). Dismissal under Rule 12(b)(6) may be based on either: (1) lack of a cognizable legal theory, or (2) insufficient facts under a cognizable legal theory. Chubb Custom Ins. Co., 710 F.3d at 956. Dismissal also is appropriate if the complaint alleges a fact that necessarily defeats the claim. Franklin v. Murphy, 745 F.2d 1221, 1228-1229 (9th Cir. 1984). II. Background This action proceeds on the first amended complaint. ECF No. 6. Therein, plaintiff alleges that in May 2023, he purchased a property in Marysville, California on an online auction. Id. at 5. He claims that, on July 20, 2023, he was notified by email that the deed to the property had been recorded in his name. Id. at 6. He went to the property the next day and inspected the property and had the locks changed. Id. That evening, Amit Tumber, the former owner of the property, arrived and verbally confronted plaintiff, demanding that he vacate the premises. Id. Tumber eventually called law enforcement and defendants Gelber and Clegg arrived. Id. at 6-7. The deputies could not conclude which individual had ownership of the property, though plaintiff alleges that his narrative of ownership had greater credibility. Id. at 7-8. Defendants eventually requested additional documentation and corroboration from plaintiff, but it was evening, and county offices had closed. Id. at 10. Additionally, there was not yet internet access at the property. Id. Unable to conclusively determine that either man had ownership of the property, the deputies ordered plaintiff to leave, concerned that violence would ensue between the two claimants after they left. Id. Plaintiff eventually reached a settlement with Tumber in February 2024, after taking legal action to recover the property. Id. at 11. He alleges that the dispossession of the property and legal proceedings necessary to recover it cost him funds that he could have used to improve the property and damaged his credit rating. Id. at 11-12. III. Analysis a. Qualified Immunity on Plaintiff’s Personal Seizure Claim Defendants argue that they are entitled to qualified immunity on plaintiff’s claim that they unlawfully seized his person. Qualified immunity precludes civil liability under 42 U.S.C. § 1983 for state officials if “their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818 (1982). Additionally, defendants may be entitled to qualified immunity “even if they acted unconstitutionally, as long as a reasonable officer could have believed the conduct lawful.” Alexander v. County of Los Angeles, 64 F.3d 1315, 1322 (9th Cir. 1995). Defendants’ argument is persuasive. First, it is unclear whether excluding an individual from a piece of real property, but otherwise allowing him full freedom of movement, amounts to a seizure of his person. See White v. City of Markham, 310 F.3d 989, 995 (7th Cir. 2002). Generally, a personal seizure occurs when “there is a restraint on liberty to the degree that a reasonable person would not feel free to leave.” Doe v. Haw. Dep’t of Educ., 334 F.3d 906, 909 (9th Cir. 2003). Here, plaintiff was not only free to leave, he was asked to do so. Obviously, leaving deprived him, at least temporarily, of the property, but as noted above, defendants are not at present challenging plaintiff’s claim that his property was unlawfully seized. Moreover, even if asking plaintiff to leave the premises did amount to an unlawful seizure of his person, defendants could have reasonably believed their conduct was lawful. The complaint acknowledges that the resources required to make a definitive finding of ownership, including county records, could not be accessed at the time defendants arrived at the property. ECF No. 1 at 10. Plaintiff also alleged that Tumber was confrontational and verbally aggressive toward him during their encounter. Id. at 6. Faced with the possibility that violence could escalate in their absence, officers could have reasonably believed that asking one of the two claimants, neither of whom had a conclusive claim of ownership, to leave was lawful. b. Procedural Due Process Claim Defendants argue that plaintiff’s procedural due process claims associated with the incident are barred by the Parratt-Hudson doctrine. In Hudson v. Palmer, the Supreme Court held that: [A]n unauthorized intentional deprivation of property by a state employee does not constitute a violation of the procedural requirements of the Due Process Clause of the Fourteenth Amendment if a meaningful postdeprivation remedy for the loss is available. For intentional, as for negligent deprivations of property by state employees, the state’s action is not complete until and unless it provides or refuses to provide a suitable postdeprivation remedy.

Wayne McKay v. Yuba County, et al., (E.D. Cal. 2025).

Wayne McKay v. Yuba County, et al. (Wayne McKay v. Yuba County, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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