Westwood Homes, Inc., et al. v. County of Sacramento, et al.

CourtDistrict Court, E.D. California
DecidedJanuary 15, 2026
Docket2:25-cv-01917
StatusUnknown

This text of Westwood Homes, Inc., et al. v. County of Sacramento, et al. (Westwood Homes, Inc., et al. v. County of Sacramento, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Westwood Homes, Inc., et al. v. County of Sacramento, et al., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 WESTWOOD HOMES, INC., et al., No. 2:25-cv-1917-CKD 12 Plaintiffs, 13 v. ORDER 14 COUNTY OF SACRAMENTO, et al., 15 Defendants.

16 17 Plaintiffs Curtis Westwood, Deborah Westwood and Westwood Homes, Inc., initiated this 18 action in the Sacramento County Superior Court in 2022. (ECF No. 1-1.) Defendants County of 19 Sacramento and Sacramento County Board of Appeals filed a notice of removal on July 8, 2025. 20 (ECF No. 1.) Pursuant to the parties’ consent and the court’s minute order on July 23, 2025, this 21 case is before the undersigned for all further proceedings including entry of final judgment. (ECF 22 No. 8.) 23 Plaintiffs’ motion for leave to file a second amended complaint is before the court. (ECF 24 No. 16.) This matter is suitable for decision without oral argument and is submitted upon the 25 briefs and records on file. See Local Rule 230(g). Accordingly, the hearing set for January 21, 26 2026, is vacated. As set forth below, the motion is denied because plaintiffs have not met 27 applicable state law time limitations for serving new defendants. 28 //// 1 I. Background 2 Plaintiffs allege the Sacramento County Planning Commission issued a Special 3 Development Permit (“SPD”) authorizing development of eight single unit condominiums on 4 their property in 2016. (ECF No. 1-3, ¶ 10.) They bring claims arising from the County’s denial 5 of building permits for Lots 1, 2, and 3 on the stated ground that encroachments into commonly- 6 owned areas and the Public Utility Easement constituted violations of the County’s Building 7 Code.1 (Id., ¶ 15.) 8 Plaintiffs commenced this action in the state superior court on April 11, 2022. Plaintiffs 9 initially brought two state law causes of action seeking writ of mandate and a third cause of action 10 for inverse condemnation brought under the California and United States Constitutions. (ECF No. 11 1-1 at 2.) The initial complaint pleaded the existence of “Doe” defendants. (Id., ¶ 6.) 12 The state superior court denied the state law claims for writ of mandate on November 18, 13 2022, leaving the third cause of action.2 On June 5, 2025, plaintiffs filed the operative first 14 amended complaint in the state superior court bringing the following causes of action: (1) inverse 15 condemnation under the California and United States Constitutions, (2) violation of substantive 16 due process under 42 U.S.C. § 1983, and (3) violation of equal protection under 42 U.S.C. § 17 1983. (ECF No. 1-3.) 18 Defendants filed the notice of removal on July 8, 2025. (ECF No. 1.) Defendants 19 answered the first amended complaint. (ECF No. 4 at 1.) Under the pretrial scheduling order, the 20 last day to seek leave to amend pleadings was December 1, 2025. (ECF No. 15 at 2.) Plaintiffs

21 1 The parties state they dispute the following issues as to those lots: “whether the encroachments were approved and are permissible under the site plans, application of the Residential Code to the 22 development, whether the County can permissibly withhold permits for further development until 23 the encroachments are removed, whether the County and its employees impermissibly and unconstitutionally conditioned issuance of the remaining permits on approvals of third parties, 24 and whether the denial of permits for the remaining lots for an approximate two (2) year period was wrongful and constituted a taking of Plaintiffs’ property rights.” (ECF No. 10 at 2-3.) 25

2 The court takes judicial notice of the existence of the December 28, 2022 order and the date on 26 which plaintiffs filed the first amended complaint. See Fed. R. Evid. 201(b); Bennett v. 27 Medtronic, Inc., 285 F.3d 801, 803 n.2 (9th Cir. 2002). This information is publicly available through the Sacramento Superior Court Civil Case Search Portal at https://prod-portal- 28 sacramento-ca.journaltech.com/public-portal/[.] 1 filed the motion for leave to amend on that date. (ECF No. 16.) 2 Plaintiffs seek leave to amend to add the following two defendants in their individual 3 capacities for the claims brought under 42 U.S.C. § 1983: Kelsey Johnson, Deputy County 4 Counsel, and Lisa Travis, County Counsel. (ECF No. 17 at 1.) Plaintiffs argue documents 5 released by the County of Sacramento indicate the proposed new defendants may have 6 coordinated the treatment plaintiffs received because of personal animus. (Id. at 5.) 7 Defendants filed an opposition to the motion for leave to amend the complaint. (ECF No. 8 19.) They argue leave to amend should be denied because the proposed amendments are time- 9 barred. (Id. at 2-11.) In particular, defendants note California’s three-year “Doe” period expired 10 months before the motion for leave to amend was filed. (Id. at 2, 9-11.) 11 Plaintiffs filed a reply. (ECF No. 20.) They argue (1) defendants lack standing to raise 12 futility arguments on behalf of new parties (ECF No. 20 at 3-4); (2) the statute of limitations 13 should be equitably tolled as to the proposed individual defendants (id. at 4-7); and (3) California 14 law does not require strict application of California Code of Civil Procedure § 474 regarding 15 adding parties (id. at 7-8). 16 II. Legal Standard 17 When a party may not amend as a matter of course, that party “may amend ... only with 18 the opposing party’s written consent or the court’s leave.” Fed. R. Civ. P. 15(a)(2). Courts in the 19 Ninth Circuit consider the following factors: “(1) bad faith, (2) undue delay, (3) prejudice to the 20 opposing party, (4) futility of amendment, and (5) whether plaintiff has previously amended its 21 complaint.” Ascon Properties, Inc. v. Mobil Oil Co., 866 F.2d 1149, 1160 (9th Cir. 1989) 22 (citation omitted); see also Foman v. Davis, 371 U.S. 178, 182 (1962). Absent prejudice or a 23 strong showing of another factor, there exists a presumption in favor of granting leave to amend. 24 See Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048, 1052 (9th Cir. 2003). 25 III. Discussion 26 “Futility of amendment can, by itself, justify the denial of a motion for leave to amend.” 27 Bonin v. Calderon, 59 F.3d 815, 845 (9th Cir. 1995). Amendment to add the proposed individual 28 defendants would be futile here because plaintiffs have not met state law time limitations 1 applicable to this case for serving the proposed individual defendants. See, e.g., Platt Elec. 2 Supply, Inc. v. EOFF Elec., Inc., 522 F.3d 1049, 1060 (9th Cir. 2008) (because Platt’s claims are 3 barred by the statute of limitations, any amendments would have been futile”). 4 The parties agree the applicable statute of limitations for the claims under 42 U.S.C. § 5 1983 is two years. See The Comm. Concerning Cmty. Improvement v.

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Bluebook (online)
Westwood Homes, Inc., et al. v. County of Sacramento, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/westwood-homes-inc-et-al-v-county-of-sacramento-et-al-caed-2026.