Eloy Mascorro v. The City of National City, Olegario Garcia, Kaitlynn Norie, Sadiq Al-Mosawi, Reynaldo Velazquez, Marc Vargas, Rowdy Pauu, Jane Does 1–2, and John Does 1–2

S.D. Cal.11/17/2025
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8                     UNITED STATES DISTRICT COURT                           
9                   SOUTHERN DISTRICT OF CALIFORNIA                          
10                                                                            
11  ELOY MASCORRO,                       Case No.:  25-CV-2172 JLS (KSC)      

12                             Plaintiff,                                     
                                        ORDER:                               
13  v.                                                                        
                                        (1) GRANTING APPLICATION TO          
14  THE CITY OF NATIONAL CITY,                                                
                                        PROCEED IN DISTRICT COURT            
   OLEGARIO GARCIA, KAITLYNN                                                 
15                                       WITHOUT PREPAYING FEES OR            
   NORIE, SADIQ AL-MOSAWI,                                                   
                                        COSTS                                
16  REYNALDO VELAZQUEZ, MARC                                                  

   VARGAS, ROWDY PAUU, JANE                                                  
17                                       (2) SCREENING COMPLAINT, AND         
   DOES 1–2, and JOHN DOES 1–2,                                              

18                                                                            
                           Defendants.  (3) DIRECTING U.S. MARSHAL TO        
19                                       EFFECT SERVICE                       

20                                                                            
                                        (ECF Nos. 1, 2)                      
21                                                                            
22       Presently before the Court is Plaintiff Eloy Mascorro’s Complaint (“Compl.,” ECF 
23  No. 1) and Application to Proceed in District Court Without Prepaying Fees or Costs (“IFP 
24  Appl.,” ECF No. 2).  Having carefully considered Plaintiff’s Complaint, Application, and 
25  the applicable law, the Court GRANTS Plaintiff’s IFP Application, DIRECTS the Clerk 
26  of Court to issue summons, and DIRECTS the U.S. Marshal to effect service. 
27  / / /                                                                     
28  / / /                                                                     
1                    IN FORMA PAUPERIS APPLICATION                           
2       All parties instituting a civil action, suit, or proceeding in a district court of the 
3  United States, other than a petition for writ of habeas corpus, must pay a filing fee of $405.1  
4  28 U.S.C. § 1914(a).  An action may proceed despite a party’s failure to pay the filing fee 
5  only if the party is granted leave to proceed in forma pauperis (“IFP”) pursuant to 28 U.S.C. 
6  § 1915(a)(1).                                                             
7       Section 1915(a)(1) provides:                                         
8            [A]ny  court  of  the  United  States  may  authorize  the      
             commencement, prosecution or defense of any suit, action or     
9                                                                            
             proceeding . . . without prepayment of fees or security therefor, 
10            by a person who submits an affidavit that includes a statement of 
             all assets such [person] possesses that the person is unable to pay 
11                                                                            
             such fees or give security therefor.                            
12                                                                            
   As § 1915(a)(1) does not itself define what constitutes insufficient assets to warrant IFP 
13                                                                            
   status, the determination of indigency falls within the district court’s discretion.  See Cal. 
14                                                                            
   Men’s Colony v. Rowland, 939 F.2d 854, 858 (9th Cir. 1991) (“Section 1915 typically 
15                                                                            
   requires the reviewing court to exercise its sound discretion in determining whether the 
16                                                                            
   affiant has satisfied the statute’s requirement of indigency.”), reversed on other grounds 
17                                                                            
   by 506 U.S. 194 (1993).  “An affidavit in support of an IFP application is sufficient where 
18                                                                            
   it alleges that the affiant cannot pay the court costs and still afford the necessities of life.”  
19                                                                            
   Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015) (citing Adkins v. E.I. Du Pont 
20                                                                            
   de Nemours & Co., 335 U.S. 331, 339 (1948)).  “One need not be absolutely destitute to 
21                                                                            
   obtain benefits of the [IFP] statute.”  Jefferson v. United States, 277 F.2d 723, 725 (9th Cir. 
22                                                                            
   1960).  “Nevertheless, a plaintiff seeking IFP status must allege poverty ‘with some 
23                                                                            
   particularity, definiteness[,] and certainty.’”  Escobedo, 787 F.3d at 1234.  
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25                                                                            

26                                                                            
   1 In addition to the $350 statutory fee, civil litigants must pay an additional administrative fee of $55.  See 
27                                                                            
   28 U.S.C. § 1914(a) (Judicial Conference Schedule of Fees, District Court Misc. Fee Schedule, § 14 (eff. 
28  Dec. 1, 2023)).  The additional $55 administrative fee does not apply to persons granted leave to proceed 
1       In Plaintiff’s IFP Application, Plaintiff states that his monthly income is $352: $292 
2  from welfare and food stamps and $60 from an unspecified “other.”  IFP App. at 2–5.  
3  Plaintiff lists his monthly expenses as $292 for food, $20 for clothing, and $30 for laundry 
4  and dry cleaning.  Id. at 4.  Plaintiff reports that he has spent or will spend $50 in legal fees 
5  in conjunction with this lawsuit.  Id. at 5.  Plaintiff lists no assets, employer, or savings 
6  beyond $17 in a PayPal account.  See generally id.                        
7       The Court is satisfied that Plaintiff has adequately demonstrated that paying the $405 
8  filing fee would result in his inability to afford the necessities of life.  Accordingly, the 
9  Court GRANTS Plaintiff’s IFP Application.                                 
10               SCREENING PURSUANT TO 28 U.S.C. § 1915(e)(2)                 
11  I.   Legal Standard                                                       
12       Because  Plaintiff  seeks  to  proceed  IFP,  his  Complaint  requires  a  pre-answer 
13  screening pursuant to 28 U.S.C. § 1915(e)(2).  See, e.g., Calhoun v. Stahl, 254 F.3d 845, 
14  845 (9th Cir. 2002) (per curiam) (holding “the provisions of 28 U.S.C. § 1915(e)(2)(B) are 
15  not limited to prisoners”); see also Lopez v. Smith, 203 F.3d 1122, 1126–27 (9th Cir. 2000) 
16  (en banc) (“[S]ection 1915(e) not only permits but requires a district court to dismiss an 
17  [IFP] complaint that fails to state a claim.”).  Under this statute, the Court sua sponte must 
18  dismiss a complaint, or any portion of it, that is frivolous, malicious, fails to state a claim, 
19  or seeks damages from immune defendants.  See Lopez, 203 F.3d at 1126–27.  “The 
20  purpose of [screening] is ‘to ensure that the targets of frivolous or malicious suits need not 
21  bear the expense of responding.’”  Nordstrom v. Ryan, 762 F.3d 903, 920 n.1 (9th Cir. 
22  2014) (citations omitted).                                                
23       “The standard for determining whether a plaintiff has failed to state a claim upon 
24  which relief can be granted under § 1915(e)(2)(B)(ii) is the same as the Federal Rule of 
25  Civil  Procedure  12(b)(6)  standard  for  failure  to  state  a  claim.”    Watison  v.  Carter, 
26  668 F.3d 1108, 1112 (9th Cir. 2012).  Rule 12(b)(6) requires a complaint to “contain 
27  sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its 
28  face.’”  Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. 
1  Twombly, 550 U.S. 544, 570 (2007)).  A claim is facially plausible “when the plaintiff 
2  pleads factual content that allows the court to draw the reasonable inference that the 
3  defendant is liable for the misconduct alleged.”  Id.  Plausibility requires pleading facts 
4  supporting a claim for relief, as opposed to conclusory allegations or the “formulaic 
5  recitation of the elements of a cause of action.”  Twombly, 550 U.S. at 555.  The “mere 
6  possibility  of  misconduct”  or  “unadorned,  the  defendant-unlawfully-harmed  me 
7  accusation[s]” fall short of meeting this plausibility standard.  Iqbal, 556 U.S. at 678–79; 
8  see also Moss v. U.S. Secret Serv., 572 F.3d 962, 969 (9th Cir. 2009).    
9       Further, courts have a duty to construe a pro se litigant’s pleadings liberally.  See 
10  Karim-Panahi v. L.A. Police Dep’t, 839 F.2d 621, 623 (9th Cir. 1988).  A district court 
11  should grant leave to amend if it appears “at all possible that the plaintiff can correct the 
12  defect.”  Lopez, 203 F.3d at 1130 (quoting Balistreri v. Pacifica Police Dep’t, 901 F.2d 
13  696, 701 (9th Cir. 1988)).                                                
14  II.  Plaintiff’s Allegations                                              
15       On August 22, 2025, Plaintiff filed the instant Complaint alleging nine causes of 
16  action pursuant to both Federal and California law.  See generally Compl.  Plaintiff alleges 
17  that Defendants, The City of National City (“National City”); Kaitlynn Norie, National 
18  City police officer; Sadiq Al-Mosawi, National City police officer; Reynaldo Velazquez, 
19  National City police officer; Marc Vargas, National City police officer; Rowdy Pauu,2 
20  National City police officer; Olegario Garcia, National City maintenance worker; Jane Doe 
21  1, unidentified plainclothes female police officer; John Doe 1, unidentified plainclothes 
22  city maintenance supervisor; Jane Doe 2, unidentified EMT/Paramedic; and John Doe 2, 
23  unidentified Internal Affairs Detective, violated his Fourth and First Amendment rights 
24  under 42 U.S.C. § 1983 and California state law.  Id. at 2–3.  Under § 1983, Plaintiff alleges 
25  false arrest, unreasonable force, retaliation, and a Monell Claim.  See generally id.  Under 
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   2 Norie, Al-Mosawi, Velazquez, Vargas, and Pauu will be referred to as “Defendant Officers” throughout 
1  California law, Plaintiff alleges malicious prosecution,  false imprisonment, intentional 
2  infliction of emotional distress, negligent infliction of emotional distress, and violations of 
3  the Tom Bane Civil Rights Act (Cal. Civ Code § 52.1).  See generally id.   
4       Specifically, Plaintiff alleges that, on or around July 25, 2024, he was wrongfully 
5  accused and arrested for brandishing a knife towards Defendant Garcia.  Id. ¶¶ 14–22.  At 
6  approximately 8 a.m., Plaintiff alleges that he was repairing a flat tire on his bicycle when 
7  Garcia approached him and accused him of littering.  Id. ¶¶ 14–15.  Plaintiff informed 
8  Garcia  that  the  debris  was  likely  from  a  nearby  maintenance  worker,  which  Garcia 
9  investigated and concluded that Plaintiff was responsible.  Id.  ¶ 14.  Garcia approached 
10  Plaintiff “displaying a hostile demeanor” and accused Plaintiff again of littering.  Id.  
11  Plaintiff, “fearing for his safety and experiencing anxiety,” told Garcia to get away and 
12  retrieved “his legally possessed pepper spray.”  Id. ¶ 15.  Plaintiff alleges that he did not 
13  brandish a knife.  Id.  Garcia returned to his vehicle and yelled, “You ain’t shit without 
14  your shit,” at Plaintiff as he walked away.  Id. ¶ 16.                    
15       Plaintiff’s cell phone, which was mounted on the bicycle, recorded the interaction.  
16  Id. ¶ 14.  Plaintiff also photographed Garcia’s “City vehicle” and recorded the scene to 
17  report the incident and “capture evidence in anticipation of further retaliatory actions from 
18  Defendant Garcia.”  Id. ¶¶ 14–19.  Plaintiff called a number noted on the city vehicle and 
19  spoke with a “female representative” requesting to file an official complaint against Garcia.  
20  Id. ¶ 17.  A “supervisor” returned Plaintiff’s call, and Plaintiff described the incident.  Id.   
21       Around 8:20 a.m., Defendant Officers Norie, Al-Mosawi, Velazquez, Vargas, and 
22  Pauu arrived at the scene in uniform.  Id. ¶ 20.  Plaintiff then alleges that each officer drew 
23  their  firearm,  pointed  them  at  Plaintiff,  and  directed  him  to  get  off  his  bike,  walk 
24  backwards, and raise his hands—with which Plaintiff complied.  Id.  Plaintiff informed 
25  them that he only “possessed a phone and a pocketknife.”  Id.  Plaintiff further complied 
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28                                                                            
   3 While unclear in the Complaint, the Court presumes that Plaintiff’s malicious prosecution claim is 
1  with  the  officers’  instructions  to  lay  on  the  ground  on  his  stomach  where  he  was 
2  handcuffed, “applying force to his arms and causing severe pain to his shoulder.”  Id. ¶ 21.   
3       Defendant Officers stated that Garcia had reported Plaintiff brandishing a knife.  Id. 
4  ¶ 22.  Plaintiff continuously attempted to explain to Defendant Officers that he had a 
5  recording of the incident and that surveillance footage from the Chamber of Commerce 
6  would demonstrate that he only retrieved his pepper spray.  Id.  Plaintiff alleges that 
7  Defendant Officers had “adequate time to conduct a thorough investigation before making 
8  an  arrest”  and  repeatedly  “ignored  Plaintiff’s  requests  to  review  the  recording  and 
9  investigate exculpatory evidence.”  Id.  Plaintiff yelled at Jane Doe 1 and John Doe 1 about 
10  the alleged exculpatory evidence and was again ignored.  Id. ¶¶ 23–24.    
11       Plaintiff complained of shoulder pain and requested medical attention, which was 
12  not addressed for forty-five (45) minutes.  Id. ¶ 27.  Jane Doe 2, a medical assistant, 
13  examined Plaintiff and “accused [him] of faking his injury, making a derogatory statement 
14  about homeless individuals,” which added to the “emotional and physical distress Plaintiff 
15  endured as a result of the arrest.”  Id.                                  
16       Plaintiff was booked at the San Diego Downtown Jail and was released seventy-two 
17  hours later with no charges filed.  Id.  Plaintiff now brings the present action requesting 
18  compensatory  damages  against  all  Defendants,  punitive  damages  against  Defendant 
19  Officers, Garcia, and Doe Defendants, and attorney’s fees.  Id. at 22.    
20  III.  Analysis                                                            
21       First, the Court must address whether Plaintiff has stated a claim under 42 U.S.C. 
22  § 1983 for purposes of establishing jurisdiction under 28 U.S.C. § 1331.  Plaintiff alleges 
23  four potential causes of action under § 1983: false arrest and unreasonable seizure under 
24  the Fourth Amendment (Claim II), excessive force under the Fourth Amendment (Claim 
25  III), retaliation under the First Amendment (Claim VIII), and unconstitutional policies, 
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28                                                                            
1  customs, and practices through a Monell Claim (Claim IX).   See generally Compl.  
2       Section 1983 “is not itself a source of substantive rights, but merely provides a 
3  method for vindicating federal rights elsewhere conferred.”  Graham v. Conner, 490 U.S. 
4  386, 393–94 (1989) (internal quotation marks and citations omitted).  To state a claim 
5  under § 1983, a plaintiff must allege both that (1) the defendant was acting under color of 
6  state law at the time the complained of act was committed, and (2) the defendant’s conduct 
7  deprived the plaintiff of a right secured by the Constitution and laws of the United States.  
8  Tsao v. Desert Palace, 698 F.3d 1128, 1138 (9th Cir. 2012) (citing Chudacoff v. Univ. 
9  Med. Ctr. of S. Nev., 649 F.3d 1143, 1149 (9th Cir. 2011)).               
10       A. Under Color of State Law                                          
11       A defendant acts under color of state law when she exercises power “possessed by 
12  virtue of state law and made possible only because the wrongdoer is clothed with the 
13  authority of state law.”  United States v. Classic, 313 U.S. 299, 326 (1941).  A defendant 
14  may act under color of state law where her conduct “satisfies the state-action requirement 
15  of the Fourteenth Amendment,” i.e., “the defendant’s alleged infringement of the plaintiff’s 
16  federal rights is ‘fairly attributable to the State.’”  West v. Atkins, 487 U.S. 42, 49 (1988) 
17  (quoting Lugar v. Edmondson Oil Co., 457 U.S. 922, 937 (1982)).  The Ninth Circuit has 
18  identified “three critical requirements that must be satisfied” for finding that a defendant 
19  has acted under color of state law: (1) the defendant pretended or purported to act in the 
20  performance of her official duties, (2) “with the purpose and effect of influencing the 
21  behavior of others,” and (3) the challenged conduct must be related in some meaningful 
22  way to the officer’s government status or performance of her duties.  Anderson v. Warner, 
23  451 F.3d 1063, 1068–69 (9th Cir. 2006) (first citing McDade v. West, 223 F.3d 1135, 1140 
24  (9th Cir. 2000); then citing Martinez v. Colon, 54 F.3d 980, 987 (1st Cir. 1995)).   
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   4 Claim II is alleged against Defendant Officers and Garcia.  Claim III is alleged against Defendant 
1       For purposes of § 1983, a police officer acts under color of state law if she is clothed 
2  with authority of the state and is purporting to act under that authority.  See Atkins, 487 
3  U.S. at 49–50 (“[A] public employee acts under color of state law while acting in his 
4  official capacity or while exercising his responsibilities pursuant to state law.”).  Therefore, 
5  Defendant Officers were acting under color of law through all the events alleged, as they 
6  were on-duty police officers engaged in their official duties.            
7       However, whether Garcia, a city maintenance worker, was acting under color of state 
8  law for allegedly falsely reporting Plaintiff requires further analysis.  Plaintiff alleges that 
9  Garcia was acting “under color of state law” for purposes of the false arrest and retaliation 
10  claims.  See Compl. ¶ 38.  While Garcia was on duty, not every action taken by a public 
11  officer on duty is taken under color of state law.  See, e.g., Savarese v. City of New York, 
12  547 F. Supp. 3d 305, 337 (S.D.N.Y. 2021) (finding that an on-duty traffic agent was not 
13  acting under color of state law when he reported a crime of which he was the alleged 
14  victim); Cruz v. Donnelly, 727 F.3d 79, 30 (3rd Cir. 1984) (“Merely calling the police and 
15  assisting them in investigating a crime does not constitute acting under the color of 
16  law. . . .”).  Acts of a public officer in furtherance of “personal pursuits” are plainly 
17  excluded from the definition of under color of state law.  Screws v. United States, 325 U.S. 
18  91, 111 (1945).                                                           
19       At the screening stage, the Court finds that Plaintiff has sufficiently alleged that 
20  Garcia was acting under color of state law when making the phone call at issue.  Plaintiff 
21  alleges that Garcia was “a maintenance worker employed by the City of National City” and 
22  was “operating a city vehicle.”  Compl. ¶¶ 3, 15.  Here, while unclear what Garcia’s role 
23  was as a city maintenance employee, Garcia may have been acting in furtherance of his 
24  duties by attempting to prevent littering.  The Court notes that it is unclear whether Garcia 
25  made the allegedly false phone call as a part of his official duties or because he felt 
26  personally victimized.  See, e.g., Muhammad v. Jenkins, No. CV 19-7970-JAK (PVC), 
27  2022 WL 363004, at * 10 (C.D. Cal. Jan. 14, 2022) (denying summary judgment as to 
28  whether the defendant city bus driver acted under color of state law because she could have 
1  called 911 either in her official capacity to protect the passengers or “purely in her self-
2  interest”).  At a later stage, with more facts, the Court may find that “[i]n reporting to the 
3  police what [Garcia] saw and experienced, he was not invoking any authority granted to 
4  him as a [public employee] but exercising the rights he had as a civilian.”  Savarese, 547 
5  F. Supp. 3d at 339.  At this stage, the Court finds that Plaintiff has sufficiently pled that 
6  Garcia was acting under color of state law.                               
7       Therefore, Plaintiff has sufficiently alleged that Defendant Officers and Garcia were 
8  acting under color of state law for purposes of a § 1983 claim.           
9       B. Deprivation of a Right Secured by the Constitution or Laws of the United States  
10       Under Section 1983, a defendant deprives another of a constitutional right if the 
11  defendant “does an affirmative act, participates in another's affirmative acts, or omits to 
12  perform an act which he is legally required to do that causes the deprivation of which [the 
13  plaintiff complains].”  Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988) (quoting Johnson 
14  v.  Duffy, 588  F.2d 740,  743  (9th  Cir.  1978)).    “The  inquiry  into  causation  must  be 
15  individualized and focus on the duties and responsibilities of each individual defendant 
16  whose acts or omissions are alleged to have caused a constitutional deprivation.”  Id.  
17            1.  42 U.S.C. § 1983 False Arrest and Unreasonable Seizure      
18       In Claim II, Plaintiff alleges that Defendant Officers and Garcia violated his Fourth 
19  Amendment right to be “free from unreasonable seizure by arresting and detaining him 
20  without probable cause.”  Compl. ¶ 38.  Plaintiff alleges that Defendant Officers were “on 
21  notice that they had received a potentially false report from [Garcia]” and that by failing to 
22  review any readily available video footage of the incident, Defendant Officers failed to 
23  reasonably investigate the absence of probable cause.  Id. ¶¶ 39–43.      
24       “A claim for unlawful arrest is cognizable under § 1983 as a violation of the Fourth 
25  Amendment,  provided  the  arrest  was  without  probable  cause  or  other  justification.”  
26  Dubner v. City and Cnty. of San Francisco, 266 F.3d 959, 964 (9th Cir. 2001); see, e.g., 
27  Cabrera v. City of Huntington Beach, 159 F.3d 374, 380 (9th Cir. 1998) (citing George v. 
28  City of Long Beach, 973 F.2d 706, 710 (9th Cir. 1992)) (stating that where an officer has 
1  probable cause to arrest, she cannot be liable for false arrest).  Probable cause exists when 
2  “there is a fair probability or substantial chance of criminal activity.”  United States v. 
3  Patayan Soriano, 361 F.3d 494, 505 (9th Cir. 2004) (quoting United States v. Bishop, 264 
4  F.3d 919, 924 (9th Cir. 2001)).  “It is well-settled that ‘the determination of probable cause 
5  is based upon the totality of the circumstances known to the officers at the time of the 
6  search.’”  Id. (quoting Bishop, 264 F.3d at 924).  “While an officer may not ignore 
7  exculpatory evidence that would negate a finding of probable cause, ‘[o]nce probable cause 
8  is established, an officer is under no duty to investigate further or to look for additional 
9  evidence which may exculpate the accused.’”  Tsao v. Desert Palace, 698 F.3d 1128, 1147 
10  (9th Cir. 2012) (quoting Broam v. Bogan, 320 F.3d 1023, 1032 (9th Cir. 2003)). 
11       In the Ninth Circuit, “[i]n establishing probable cause, officers may not solely rely 
12  on the claim of a citizen witness that he was a victim of a crime, but must independently 
13  investigate the basis of the witness’ knowledge or interview other witnesses.”  Arpin v. 
14  Santa Clara Valley Transp. Agency, 261 F.3d 912, 925 (9th Cir. 2001) (citing Fuller v. 
15  M.G. Jewelry, 950 F.2d 1437, 1444 (9th Cir. 1991)); see also Hopkins v. Bonvicino, 573 
16  F.3d 752, 767 (9th Cir. 2009) (“[S]tatements from a witness, without further investigation 
17  by the police, are insufficient to support probable cause.”).  While officers can rely upon 
18  information from a witness to establish reasonable suspicion for a Terry stop, they cannot 
19  establish probable cause solely on witness information.  See Thomas v. City of Portland, 
20  No. 05-1059-ST, 2007 WL 2286254, at *11 (D. Or. Aug. 3, 2007) (first citing Adams v. 
21  Williams, 407 U.S. 143, 147 (1972); then citing Fuller, 950 F.2d at 1444); see also Smith 
22  v. City of the Dalles, No. 16-cv-1771-SI, 2021 WL 2287421, at *16–19 (D. Or. June 4, 
23  2021) (finding reasonable suspicion for a Terry stop, but not probable cause to arrest 
24  because the officer had only the uncorroborated citizen witness 911 testimony, did not 
25  question plaintiff beyond a general denial, and did not interview the reporting witness or 
26  any other potential witnesses).                                           
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28  / / /                                                                     
1                 a.  Defendant Officers                                     
2       Here, Defendant Officers  responded to  a  call  that Plaintiff  “pulled a  knife,” a 
3  potential violation of California Penal Code § 417.5  Compl. Ex A. at 25.  This report from 
4  an  identified  911  caller,  Garcia,  corroborated  by  Plaintiff  at  the  scene  possessing  a 
5  pocketknife, created reasonable suspicion to justify a Terry stop.  See, e.g., Terry v. Ohio, 
6  392 U.S. 1 (1968); United States v. Terry-Crespo, 356 F.3d 1170, 1174–77 (9th Cir. 2004) 
7  (finding that a non-anonymous 911 call created reasonable suspicion, as the police could 
8  “place  additional  reliability”  on  a  “victim-informant”  who  sought  immediate  police 
9  assistance); U.S. v. Drake, 456 F.3d 771, 775 (7th Cir. 2006) (“We therefore presume the 
10  reliability of an eyewitness 911 call reporting an emergency situation for purposes of 
11  establishing reasonable suspicion, particularly when the caller identifies herself . . . [and] 
12  provide[s] sufficient details to allow the officers to identify the suspects.”).   
13       However, Defendant Officers needed probable cause to physically restrain Plaintiff 
14  with handcuffs—absent legitimate safety concerns for officers or an intention to evade 
15  arrest, neither of which are present here.6  See City of the Dalles, 2021 WL 2287421, at *8 
16  (first citing Washington v. Lambert, 98 F.3d 1181, 1186 (9th Cir. 1996); then citing United 
17                                                                            
18                                                                            
19                                                                            
20                                                                            
   5 California Penal Code § 417(a)(1) makes it a misdemeanor to “draw[] or exhibit[] any deadly weapon 
   whatsoever, other than a firearm, in a rude, angry, or threatening manner.”  Plaintiff’s arrest report 
21  demonstrates he was arrested for this offense.  Specifically, for being armed with a “[l]ethal [c]utting 
   [i]nstrument.”  See Compl. Ex. A at 26.                                   
22  6 To distinguish between a Terry stop and an arrest, courts “consider whether a reasonable person would 
   believe that he or she is being subjected to more than a temporary detention, as well as the justification 
23                                                                            
   for the use of such tactics, i.e., whether the officer had sufficient basis to fear for his safety to warrant the 
24  intrusiveness of the action taken.”  United States v. Brown, 996 F.3d 998, 1006 (9th Cir. 2021) (internal 
   citations omitted).  “When considering the safety concerns of the officers, [courts analyze] ‘the severity 
25  of the crime at issue’ and ‘whether the suspect poses an immediate threat to the safety of the officers or 
   others.’”  City of the Dalles, 2021 WL 2287421, at *8 (quoting Green v. City & Cnty. of San Francisco, 
26  751 F.3d 1039, 1049 (9th Cir. 2014)).  Here, taking Plaintiff’s allegations as true, Plaintiff complied with 
   all Defendant Officers’ requests and did not pose a threat to their safety.  Plaintiff was handcuffed and 
27                                                                            
   placed on the ground on his stomach by Defendant Officers whose firearms were drawn.  This is sufficient 
28  to allege that the stop had turned into an arrest, as Plaintiff reasonably did not feel free to leave and could 
1  States v. Cervantes-Flores, 421 F.3d 825, 830 (9th Cir. 2005), overruled on other grounds 
2  by, Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009)).                 
3       Upon  arriving  at  the  scene,  Defendant  Officers,  with  their  firearms  drawn, 
4  approached Plaintiff and asked him to get off his bike, walk backwards towards them, and 
5  lay on the ground on his stomach.  Compl. ¶¶ 20–21.  Plaintiff complied and informed them 
6  that “he only possessed a phone and a pocketknife,” that they had received a false report, 
7  and that the incident was recorded and easily accessible.  Id. ¶¶ 21–22.  Taking Plaintiff’s 
8  allegations  as  true,  at  no  point  did  Defendant  Officers  investigate  any  of  Garcia’s 
9  allegations.  They did not review the video footage—whether Plaintiff’s own or any 
10  surrounding surveillance footage from the Chamber of Commerce—nor did they make any 
11  efforts to “independently investigate the basis of the witness’ knowledge or interview other 
12  witnesses.”  Arpin, 261 F.3d at 925 (citing Fuller, 950 F.2d at 1444); City of the Dalles, 
13  2021 WL 2287421, at *16–19; see also Hopkins, 573 F.3d at 767 (finding that officers did 
14  not have probable cause when they obtained no information beyond the witness’s report); 
15  Vuz v. DCSS III, Inc., 20-cv-246-GPC-AGS, 2020 WL 4366023, at * 11 (S.D. Cal. July 
16  30, 2020) (surviving a motion to dismiss by alleging that officers only interviewed the 
17  reporting witnesses and no other witnesses).  Defendant Officers still had an obligation to 
18  investigate exculpatory evidence as probable cause had not been established.  See Tsao, 
19  698 F.3d at 1147.                                                         
20       However, for an individual defendant to be liable under § 1983 there must be a 
21  showing of personal participation in the rights deprivation.  See Smith v. City of Marina, 
22  709 F. Supp. 3d 926, 934 (N.D. Cal. 2024) (dismissing and granting leave to amend to 
23  clarify which defendants were responsible for which conduct).  There is no “team effort” 
24  standard which allows a plaintiff to lump all the defendants together, rather than base 
25  liability on each defendant’s actions.  See Hopkins, 573 F.3d at 770–71 (citing Chuman v. 
26  Wright, 76 F.3d 292, 295 (9th Cir. 1996)).  Under the “integral participant” rule, liability 
27  can be extended to those actors who were “integral participants in the constitutional 
28  violation, even if they did not directly engage in the unconstitutional conduct themselves.”  
1  Id.  Here, Plaintiff alleges that all Defendant Officers failed to investigate exculpatory 
2  evidence and participated in his unlawful arrest.  See Compl. ¶ 38.  At the screening stage, 
3  the Court finds that Plaintiff has alleged sufficient facts that each Defendant Officer was 
4  an “integral participant” in the incident.  See Peck v. Montoya, 51 F.4th 877, 889 (9th Cir. 
5  2022) (holding the integral participant satisfied where “the defendant knows about and 
6  acquiesces in the constitutionally defective conduct as part of a common plan with those 
7  whose conduct constitutes the violation”); see Lacroix v. Howard, No. 22-cv-1956-WQH-
8  BLM, 2023 WL 6120613, at 2–3 (S.D. Cal. Sept. 18, 2023) (finding that plaintiff’s 
9  allegations survived the “low threshold for screening” using the integral participant rule). 
10       Therefore, Plaintiff has sufficiently alleged a false arrest claim against Defendant 
11  Officers.                                                                 
12                 b.  Garcia                                                 
13       To allege a Fourth Amendment violation by a non-law enforcement governmental 
14  party, Plaintiff must demonstrate that Garcia acted “with the intent to assist the government 
15  in its investigatory or administrative purposes, and not for an independent purpose.”  Arpin, 
16  261 F.3d at 924 (internal quotation marks omitted) (quoting United States v. Attson, 900 
17  F.2d 1427, 1429 (9th Cir. 1990)).  If Plaintiff can demonstrate that Garcia’s conduct is 
18  subject  to  the  Fourth  Amendment,  Garcia  violated  Plaintiff’s  rights  if,  “under  the 
19  circumstances  apparent  at  the  time,”  Garcia  “unreasonably  caused  the  restriction  of 
20  [Plaintiff’s] liberty.”  See id.  Here, Plaintiff alleges that Garcia was a city maintenance 
21  worker who approached Plaintiff and falsely accused him of littering.  Compl. ¶¶ 15–16.  
22  After a hostile interaction, Plaintiff felt threatened and pulled out his pepper spray.  Id.  
23  Plaintiff reported Garcia to his supervisors; then Garcia reported Plaintiff to the police.  Id. 
24  ¶ 17, Ex. A at 26.  From these facts, it could be plausibly inferred that Garcia called the 
25  police not for an independent purpose, but as a governmental employee acting with the 
26  intent to assist National City in preventing littering.  See Arpin, 261 F.3d at 924.  It is 
27  plausible that Garcia reported the incident to the police maliciously to provide a means 
28  where the police would take him into custody—potentially violating Plaintiff’s Fourth 
1  Amendment right.  See id.  Therefore, at the screening stage, Plaintiff alleged sufficient 
2  facts that Garcia was acting on behalf of National City and subjected Plaintiff to an 
3  unreasonable seizure.                                                     
4       Accordingly, Plaintiff sufficiently stated a claim for false arrest and unreasonable 
5  seizure under § 1983 against Defendant Officers and Garcia.               
6            2.  42 U.S.C. § 1983 Unreasonable Force Under the Fourth Amendment 
7       In Claim III, Plaintiff alleges that Defendant Officers used “objectively unreasonable 
8  and excessive force” when they handcuffed him “while he was lying prone, forcefully and 
9  unnecessarily yanking his arms behind his back.”  Compl. ¶¶ 46–48.  Plaintiff states that 
10  he “was compliant, posed no immediate threat to the officers or others, and made no 
11  attempt to resist arrest.”  Id. ¶ 49.  Plaintiff allegedly suffered “a rotator cuff injury, physical 
12  pain, emotional distress, and fear.”  Id. ¶ 50.                           
13       Under the Fourth Amendment, the amount of force used in a seizure or arrest must 
14  be “objectively reasonable” under the circumstances.  Graham v. Connor, 490 U.S. 386, 
15  397 (1989).  The Ninth Circuit employs a three-step analysis for evaluating reasonableness 
16  under Graham.  See Harmon v. City of Pocatello, 854 Fed. App’x 850, 853 (9th Cir. 2021).  
17  First, the court must assess “the gravity of the particular intrusion on Fourth Amendment 
18  interests by evaluating the type and amount of force inflicted.”  Id. (citing Miller v. Clark 
19  Cnty., 340 F.3d 959, 964 (9th Cir. 2003)).  Second, the court assesses the “importance of 
20  the government interests at stake” by considering: “(1) the severity of the crime at issue, 
21  (2) whether the suspect posed an immediate threat to the safety of the officers or others, 
22  and (3) whether the suspect was actively resisting arrest or attempting to evade arrest by 
23  flight.”  Id.  Third, the court must balance the gravity of the intrusion on the person against 
24  the government’s need.  Id.                                               
25       Here, Plaintiff states that from a distance of “30-40 feet” all Defendant Officers drew 
26  their firearms and pointed them at Plaintiff.  Compl. ¶ 20.  Plaintiff further claims that 
27  while he was lying on the ground, Defendant Officers approached him with their guns 
28  drawn and “forcefully” pulled his arms behind his back and handcuffed him.  Id. ¶ 21.  
1  Regarding the gravity of the intrusion, the Ninth Circuit has found that pointing a gun at 
2  someone may constitute excessive force, even if it does not cause injury.  See Tekle v. 
3  United States, 511 F.3d 839, 845 (9th Cir. 2007) (citing Robinson v. Solano Cnty., 278 F.3d 
4  1007, 1014–15 (9th Cir. 2002) (en banc)).  Further, “wrenching” someone’s arm back when 
5  they are suspected of a low-level misdemeanor, presented no threat to officers, and did not 
6  resist or fight back, has been found sufficient to state a claim for excessive force.  See 
7  Hulet v. Cnty. of Tuolumne, 23-cv-1217-KES-HBK, 2024 WL 3758360, at *10 (E.D. Cal. 
8  Aug. 12, 2024); see also Bryan v. MacPherson, 630 F.3d 805, 828–29 (9th Cir. 2010) 
9  (citing Headwaters Forest Def. v. Cnty. of Humboldt, 240 F.3d 1185, 1204 (9th Cir. 2000), 
10  vacated and remanded on other grounds, 534 U.S. 801 (2001)) (“While the commission 
11  of a misdemeanor offense is not to be taken lightly, it militates against finding the force 
12  used to effect an arrest reasonable where the suspect was also nonviolent and posed no 
13  threat to the safety of the officers or others.” (internal quotation marks omitted)).  
14       Plaintiff was suspected of violating California Penal Code § 417, a misdemeanor.  
15  Compl. Ex A at 26.  While Plaintiff was accused of threatening Garcia with a knife and 
16  reported  to  Defendant  Officers  that  he  did  have  a  pocketknife,  based  on  Plaintiff’s 
17  allegations, he complied with all the Officers’ requests, did not attempt to resist arrest, and 
18  was not a threat to the Officers.  Id. ¶¶ 20–22.  “The most important Graham factor is 
19  whether the suspect posed an immediate threat to anyone’s safety.”  Nehad v. Browder, 
20  929 F.3d 1125, 1132 (9th Cir. 2019) (citing Mattos v. Agarano, 661 F.3d 433, 441 (9th Cir. 
21  2011) (en banc)).  Taking Plaintiff’s account of the events as true, Plaintiff did not pose a 
22  threat to the Officers.  Plaintiff has sufficiently stated a claim that Defendant Officers 
23  alleged extended use of firearms and forceful pulling on Plaintiff’s arm to restrain him was 
24  not objectively reasonable under the circumstances.                       
25       As discussed above, for an individual defendant to be liable under § 1983 there must 
26  be a showing of personal participation in the rights deprivation.  See Hopkins, 573 F.3d at 
27  770–71 (citing Chuman, 76 F.3d at 295).  Here, Plaintiff alleges that all Defendant Officers 
28  had their firearms drawn throughout the encounter; however, Plaintiff does not state which 
1  Officer was responsible for pulling his arms behind his back.  See Compl. ¶¶ 44–50.  
2  Nevertheless, the Court finds that Plaintiff has alleged sufficient facts to state a claim for 
3  excessive force as he has alleged that each Defendant Officer was an “integral participant” 
4  in the alleged violation.  See Boyd v. Benton Cnty., 374 F.3d 773, 780 (9th Cir. 2004) 
5  (finding that officers providing backup were integral participants in another officer’s use 
6  of excessive force); see also Blankenhorn v. City of Orange, 485 F.3d 463, 480 n.12 (9th 
7  Cir. 2007) (concluding that an officer who helped handcuff the plaintiff was an integral 
8  participant in the other officers’ use of excessive force).               
9       Therefore, Plaintiff has sufficiently alleged excessive force pursuant to § 1983 
10  against Defendant Officers.                                               
11            3.  42 U.S.C. § 1983 Retaliation Under the First Amendment      
12       In Claim VII, Plaintiff alleges that Garcia violated his First Amendment rights by 
13  calling  the  police  with  false  accusations  in  retaliation  for  Plaintiff  calling  Garcia’s 
14  supervisors.  Compl. ¶¶ 83–87.  Plaintiff alleges that he called National City to report 
15  Garcia’s “hostile and threatening behavior” while Garcia “was within earshot.”  Id. ¶ 84, 
16  86.  Garcia then allegedly “immediately followed up with the false report that led to the 
17  arrest.”  Id. ¶ 86.                                                       
18       A plaintiff can bring a § 1983 claim alleging that a public official “took action with 
19  the intent to retaliate against, obstruct, or chill the plaintiff’s First Amendment rights.”  
20  Arizona Students’ Ass’n v. Arizona Bd. of Regents, 824 F.3d 858, 867 (9th Cir. 2016) (citing 
21  Gibson v. United States, 781 F.2d 1334, 1338 (9th Cir. 1986)).  A plaintiff must allege that 
22  “(1) [she] engaged in constitutionally protected activity; (2) the defendant’s actions would 
23  ‘chill a person of ordinary firmness’ from continuing to engage in the protected activity; 
24  and  (3)  the  protected  activity  was  a  substantial  motivating  factor  in  the  defendant’s 
25  conduct—i.e., that there was a nexus between the defendant’s actions and an intent to chill 
26  speech.”  Id. (citing O’Brien v. Welty, 818 F.3d 920, 933–34 (9th Cir. 2016)).  To succeed, 
27  a plaintiff need only demonstrate the defendant “intended to interfere” with plaintiff’s First 
28  Amendment rights and plaintiff suffered an injury as a result; a plaintiff is not required to 
1  prove that their speech was inhibited.  Id. (citing Mendocino Envt’l Ctr. v. Mendocino 
2  Cnty., 192 F.3d 1283, 1300 (9th Cir. 1999)).                              
3       First, Plaintiff alleges that he engaged in a constitutionally protected activity when 
4  he called National City to report Garcia’s “hostile and threatening behavior.”  Compl. ¶ 84.  
5  He alleges that reporting misconduct by a government employee is a matter of public 
6  concern and is protected under the First Amendment.  Id.  “[T]he law is settled that . . . the 
7  First  Amendment  prohibits  government  officials  from  subjecting  an  individual  to 
8  retaliatory actions, including criminal prosecutions, for speaking out.”  Hartman v. Moore, 
9  547 U.S. 250, 256 (2006) (citing Crawford-El v. Britton, 523 U.S. 574, 592 (1998)).  
10  Further, “[u]nlawful conduct by a government employee . . . is a matter of public concern.”  
11  Thomas v. City of Beaverton, 379 F.3d 802, 809 (9th Cir. 2004); see also Eng v. Cooley, 
12  552 F.3d 1062, 1075 (9th Cir. 2009) (finding that speech by a citizen on matters of public 
13  concern was a clearly established First Amendment right).  Therefore, because Plaintiff 
14  was reporting alleged government employee misconduct, Plaintiff has sufficiently alleged 
15  that he was engaged in constitutionally protected speech.                 
16       Second, Plaintiff alleges that Garcia’s false report to the police resulting in his arrest, 
17  subjection to excessive force, and three-day detention would “chill or deter a person of 
18  ordinary firmness from continuing to engage in that activity.”  Compl. ¶ 85.  The Ninth 
19  Circuit has found that retaliatory police action like an arrest or search and seizure would 
20  “chill a person of ordinary firmness from engaging in future First Amendment activity.”  
21  Ford v. City of Yakima, 706 F.3d 1188, 1193 (9th Cir. 2013), abrogated on other grounds 
22  by, Nieves v. Bartlett, 587 U.S. 391 (2019) (finding that allegations of being booked and 
23  jailed in retaliation for one’s speech is sufficient); see also Bronner v. San Francisco Super. 
24  Ct., No. C 09-5001 SI, 2010 WL 2650500, at *5 (N.D. Cal. July 1, 2010) (citing Landrigan 
25  v. City of Warwick, 628 F.2d 736, 744–45 (1st Cir. 1980)) (noting that a false police report 
26  can provide the basis for a § 1983 action if a constitutional harm flows from the report).  
27  Here, Plaintiff alleges that he was arrested based solely on Garcia’s false report to the 
28  police, and this report was due to his constitutionally protected report of Garcia’s behavior 
1  to the city.  Plaintiff has sufficiently alleged that being arrested, subjected to alleged 
2  excessive force, and detained for three days would chill a person of ordinary firmness from 
3  engaging in protected speech.                                             
4       Third, Plaintiff alleges that his report to the city supervisors was a substantial or 
5  motivating factor in Garcia’s decision to call the police because Garcia was within earshot 
6  of Plaintiff’s phone call to the city and “immediately followed up with the false report.”  
7  Compl.  ¶  86.    “[T]iming  can  properly  be  considered  as  circumstantial  evidence  of 
8  retaliatory intent.”  Pratt v. Rowland, 65 F.3d 802, 808 (9th Cir. 1995) (citing Soranno’s 
9  Gasco, Inc. v. Morgan, 874 F.2d 1310, 1316 (9th Cir. 1989)); see also Beck v. City of 
10  Upland, 527 F.3d 853, 868 (9th Cir. 2008) (“[A plaintiff’s] showing of a heated personal 
11  confrontation followed by a hasty arrest likewise could rationally support a finding of 
12  retaliatory animus.”).  “Because direct evidence of retaliatory intent rarely can be pleaded 
13  in a complaint, allegation of a chronology of events from which retaliation can be inferred 
14  is sufficient to survive dismissal.”  Watison v. Carter, 668 F.3d 1108, 1114 (9th Cir. 2012) 
15  (citing Pratt, 65 F.3d at 808)).  Plaintiff must show that the adverse action would not have 
16  been taken absent the retaliatory motive.  Capp v. Cnty. of San Diego, 940 F.3d 1046, 1053 
17  (9th Cir. 2019) (citing Hartman, 547 U.S. at 259).                        
18       Here, Garcia and Plaintiff got into a heated argument evidenced by Garcia yelling, 
19  “You ain’t shit without your shit.”  Compl. ¶ 16.  Plaintiff then immediately called the 
20  phone number written on the back of Garcia’s city vehicle and spoke with a “supervisor” 
21  about the interaction, which Garcia allegedly overheard.  Id. ¶¶ 17, 86.  Defendant Officers 
22  then arrived and arrested Plaintiff.  Id. ¶ 86.  As discussed above, this arrest was likely 
23  without probable cause and based primarily if not solely on Garcia’s report.  It is plausible 
24  that Garcia’s allegedly false report was motivated by Plaintiff’s call to his supervisors as 
25  he was within earshot.  Therefore, Plaintiff has adequately stated a claim that Garcia acted 
26  with an intent to chill.  See, e.g., Toler v. Paulson, 551 F. Supp. 2d 1039, 1048 (E.D. Cal. 
27  2008) (stating a claim for First Amendment retaliation where plaintiff publicly criticized 
28  the District Attorney’s Office, and a DA investigator subsequently filed a false petition for 
1  a TRO); Johnson v. Erickson, 20-cv-4168-KES, 2021 WL 201725, at *2 (D.S.D. Jan. 20, 
2  2021) (stating a claim for First Amendment retaliation by alleging that a parole officer filed 
3  a false report leading to plaintiff’s arrest because plaintiff told him about a lawsuit he was 
4  filing against the officer); cf. Vermeulen v. Jenkins, No. 13-cv-2007-LJO-BAM, 2014 WL 
5  2154448, at *3 (E.D. Cal. May 22, 2014) (dismissing retaliation claim because plaintiff 
6  failed  to  allege  that  defendants  had  any  knowledge  of  the  alleged  criticism  causing 
7  retaliation).                                                             
8       As discussed above, Plaintiff has plausibly alleged that Garcia was acting in his role 
9  of a city employee when he made the phone call in question.  Therefore, Plaintiff has 
10  adequately stated a claim for retaliation under § 1983.                   
11            4.  42 U.S.C. § 1983 Monell Claim                               
12       In Claim IX, Plaintiff alleges that National City is liable for deprivations of his 
13  constitutional rights resulting from their formal policies or customs under Monell.  See 
14  Compl. ¶ 89; Monell v. New York City Dep’t of Soc. Servs., 436 U.S. 658, 691–95 (1978).  
15  Plaintiff alleges that National City inadequately trains its police officers on de-escalation 
16  tactics and the appropriate use of force.  Compl. ¶ 89.  Plaintiff further alleges that National 
17  City has a policy and custom of “inadequately investigating citizen complaints of police 
18  misconduct” and ratifying police misconduct by failing to discipline officers.  Id. ¶¶ 90–
19  91.                                                                       
20       A  local  government,  such  as  National  City,  can  be  sued  under  §  1983  for 
21  deprivations  of  constitutional  rights  resulting  from  their  formal  policies  or  customs.  
22  Monell, 436 U.S. at 691–95.  To hold a municipality liable, a plaintiff must allege: (1) the 
23  plaintiff was deprived of a constitutional right, (2) the municipality had a policy, (3) this 
24  policy amounts to deliberate indifference to the plaintiff’s rights, and (4) the policy is the 
25  moving force behind the violation.  Van Ort v. Estate of Stanewich, 92 F.3d 831, 837 (9th 
26  Cir. 1996) (quoting Oviatt v. Pearce, 945 F.2d 1470, 1474 (9th Cir. 1992)).  “Municipalities 
27  may be liable under § 1983 for constitutional injuries pursuant to: (1) an official policy; (2) 
28  a pervasive practice or custom; (3) a failure to train, supervise or discipline; or (4) a 
1  decision or act by a final policymaker.”  Horton by Horton v. City of Santa Maria, 915 
2  F.3d 592, 602–03 (9th Cir. 2019) (citing Monell, 435 U.S. at 693–95).     
3        Here, Plaintiff alleges failure to train officers on use of excessive force and de-
4  escalation techniques, a pervasive practice of failing to investigate citizen complaints of 
5  police misconduct, and ratification of police misconduct by failure to discipline officers.  
6  Compl. ¶¶ 89–91.                                                          
7                 a.  Failure to Train                                       
8       Plaintiff must sufficiently allege that National City’s failure to train amounted to 
9  “deliberate indifference to the rights of persons with whom the police come into contact.”  
10  City of Canton v. Harris, 489 U.S. 378, 388 (1989).  A failure to train must reflect “a 
11  deliberate or conscious choice by a municipality.”  Id. at 389 (internal quotation marks 
12  omitted).  “Deliberate indifference is a stringent standard of fault, requiring proof that a 
13  municipal actor disregarded a known or obvious consequence of his action.”  Connick v. 
14  Thompson, 563 U.S. 51, 61 (2011) (internal quotation marks omitted) (quoting Bd. of Cnty. 
15  Com’rs of Bryan Cnty. v. Brown, 520 U.S. 397, 410 (1997)).  When city policymakers are 
16  “on actual or constructive notice that a particular omission in their training program causes 
17  city employees to violate citizens’ constitutional rights,” the city may be found deliberately 
18  indifferent if they chose to retain that program.  Id.  To demonstrate that failure to train 
19  amounts to deliberate indifference, it is “ordinarily necessary to demonstrate a pattern of 
20  similar constitutional violations by untrained employees.”  Scalia v. Cnty. of Kern, 308 F. 
21  Supp.  3d.  1064,  1078  (E.D.  Cal.  2018)  (internal  quotation  marks  omitted)  (quoting 
22  Connick, 563 U.S. at 62).                                                 
23       Here,  Plaintiff  alleges,  in  a  conclusory  manner,  that  the  actions  of  Defendant 
24  Officers the day of the incident were “a direct result” of inadequate training by National 
25  City.  Compl. ¶ 89.  Alleging misconduct on the part of a handful of officers is insufficient 
26  to allege a program-wide policy of deliberate indifference.  See Hyde v. City of Willcox, 23 
27  F.4th 863, 874 (9th Cir. 2022) (“While deliberate indifference can be inferred from a single 
28  incident when the unconstitutional consequences of failing to train are patently obvious 
1  . . . an inadequate training policy itself cannot be inferred from a single incident.” (internal 
2  citations  omitted)).    Plaintiff  attempts  to  allege  a  “pattern  of  similar  constitutional 
3  violations” based on the cases of McNeil v. City of National City and Cummins v. City of 
4  National City.7  Compl. ¶ 92.  However, Plaintiff does not allege factual similarities 
5  between these cases and the current incident and does not allege any other instances of 
6  excessive force to suggest a failure to train.  See Hendrix v. City of San Diego, 20-CV-45 
7  TWR (NLS), 2021 WL 3892671, at *8 (S.D. Cal. Aug. 11, 2021) (dismissing a failure to 
8  train claim because plaintiff did not allege similar constitutional violations to the one at 
9  issue); Zahn v. Flathead Cnty., CV 23-65-M-DLC, 2024 WL 1374723, at *5 (D. Mont. 
10  Apr. 1, 2024) (finding that citing to four other prior shootings was insufficient to show a 
11  custom because plaintiff failed to allege factual similarities or constitutional violations);  
12  Gonzalez v. City of Huntington Beach, SA CV 18-953-DOC (DFMx), 2018 WL 9537311, 
13  at *7 (C.D. Cal. Oct. 12, 2018) (dismissing a failure to train claim because plaintiff solely 
14  relied on the incident in question).                                      
15       Therefore, Plaintiff’s failure to train Monell claim is DISMISSED WITH LEAVE 
16  TO AMEND to allow Plaintiff to allege a pattern of similar constitutional violations.   
17                 b.  Policy or Custom of Failure to Investigate Citizen Complaints  
18       Plaintiff further alleges that National City has a policy and custom of “inadequately 
19  investigating  citizen  complaints  of  misconduct,”  which  “discourages  citizens  from 
20  reporting misconduct and creates an environment where officers believe they can act with 
21  impunity.”  Compl. ¶ 90.  Plaintiff alleges that this failure to investigate patterns of 
22                                                                            
23                                                                            
24                                                                            
   7 The Court presumes that Plaintiff is referring to Davis v. City of National City, 19-cv-534-AJB-AHG, 
   2020 WL 6799380 (S.D. Cal. Nov. 19, 2020) and Cummins v. City of Nat’l City, 37-2022-00004671-CU-
25  OE-CTL, 2023 Cal. Super. LEXIS 36971 (S.D. Super. Ct. May 26, 2023), generally.  See John Carroll, 
   National City Oks $300K Settlement With Early McNeil’s Family, KPBS (Sept. 22, 2021 at 1:33 PM PDT), 
26  https://www.kpbs.org/news/public-safety/2021/09/22/national-city-approves-300000-settlement-family-
   ea; Jeff McDonald & Tammy Murga, Jury awards $10M to former officer who accused National City 
27                                                                            
   police  of  discrimination,  harassment,  SAN  DIEGO  UNION-TRIBUNE  (Apr.  1,  2025), 
28  https://www.sandiegouniontribune.com/2025/04/01/jury-awards-10m-to-former-officer-who-accused-
1  excessive force “perpetuates this unconstitutional custom” and ultimately led to Defendant 
2  Officers’ failure to investigate possible exculpatory evidence, Plaintiff’s false arrest, and 
3  prolonged detention.  Id.                                                 
4       Allegations of an unconstitutional policy or custom will be sufficient where they 
5  “(1) identify the challenged policy/custom; (2) explain how the policy/custom is deficient; 
6  (3) explain how the policy/custom caused the plaintiff harm; and (4) reflect how the 
7  policy/custom amounted to deliberate indifference.”  Herd v. Cnty. of San Bernardino, 311 
8  F. Supp. 3d 1157, 1167 (C.D. Cal. 2018) (quoting Young v. City of Visalia, 687 F. Supp. 
9  2d 1141, 1163 (E.D. Cal 2009)).  This policy must be the proximate cause of the § 1983 
10  injury.  Van Ort, 92 F.3d at 837 (citing Mann v. City of Tucson, Dep’t of Police, 782 F.2d 
11  790, 793 (9th Cir. 1986)).                                                
12       Here, Plaintiff again alleges in a conclusory manner that there is a policy or custom 
13  of inadequately investigating citizen complaints and attempts to connect the potential 
14  constitutional violations by Defendant Officers to this alleged custom.  See Compl. ¶ 90.  
15  Plaintiff has failed to allege any facts that this policy or custom exists or, assuming the 
16  policy does exist, how it led to a constitutional violation in this case.  See Hendrix, 2021 
17  WL 3892671, at *10 (dismissing a policy/custom Monell claim because plaintiff failed to 
18  allege  that  the  policy  in  question  exists,  that  it  was  the  “moving  force”  behind  the 
19  constitutional violation, and how that policy reflected deliberate indifference on the part of 
20  the city).                                                                
21       Therefore, Plaintiff’s policy/custom Monell claim is DISMISSED WITH LEAVE 
22  TO AMEND.                                                                 
23                 c.  Ratification                                           
24       Plaintiff further alleges that National City ratifies and condones “unconstitutional 
25  conduct  of  its  officers,  including  excessive  force,  false  arrest,  and  First  Amendment 
26  retaliation, by failing to discipline officers involved in prior incidents of misconduct.”  
27  Compl. ¶ 91.  To support this assertion, Plaintiff alleges that after his release from custody, 
28  he went to the National City Police Department Headquarters to file a formal complaint.  
1  Id.  Plaintiff then alleges that “[a]n Internal Affair Detective (John Doe 2)” stated he was 
2  aware of the arrest and that the officers followed their training.  Id.   
3       Plaintiff has failed to allege a ratification claim.  To plead ratification, a plaintiff 
4  must allege that the “authorized policymakers approve[d] a subordinate’s decision and the 
5  basis for it.”  Lytle v. Carl, 382 F.3d 978, 987 (9th Cir. 2004).  “The policymaker must 
6  have knowledge of the constitutional violation and actually approve of it. . . .”  Herd, 311 
7  F. Supp. 3d at 1167 (citing Lytle, 382 F.3d at 987)).  Assuming an Internal Affair Detective 
8  qualifies as an “authorized policymaker,” Plaintiff needs to allege more than a singular 
9  incidence of an alleged failure to discipline.  See Koenig v. City of Bainbridge Island, No. 
10  C10-5700 RJB, 2011 WL 3759779, at *8 (W.D. Wash. Aug. 25, 2011) (“[I]n order for 
11  there to be ratification, there must be something more than a single failure to discipline or 
12  the fact that a policymaker concluded that the defendant officer’s actions were in keeping 
13  with the applicable policies and procedures.” (internal citations omitted)); see Dodge v. 
14  Evergreen Sch. Dist. #114, 56 F.4th 767, 788 (9th Cir. 2022) (finding that a failure to 
15  discipline does not meet the requirements of ratification).               
16       Therefore, Plaintiff’s ratification Monell claim is DISMISSED WITH LEAVE TO 
17  AMEND.                                                                    
18       C. California State Law Claims                                       
19       As Plaintiff has stated a claim under § 1983, the Court now considers Plaintiff’s 
20  allegations  under  California  law.    Plaintiff  alleges:  (1)  malicious  prosecution  against 
21  Garcia,  (2)  false  imprisonment  against  “Defendants,”8  (3)  intentional  infliction  of 
22  emotional distress against Garcia and Jane Doe 2, (4) negligent infliction of emotional 
23  distress against Defendant Officers, and (5) violations of the Tom Bane Civil Rights Act 
24  against Defendant Officers and Garcia.  See generally Compl.  The Court considers each 
25  in turn.                                                                  
26                                                                            

27  8 Plaintiff does not specify which Defendants this claim is brought against.  See Compl. ¶¶ 51–55.  The 
28  Court assumes Plaintiff brings this claim against Defendant Officers as the false imprisonment section 
1            1.  Malicious Prosecution                                       
2       In Claim I, Plaintiff alleges that Garcia made a false report resulting in Plaintiff’s 
3  arrest  and  subsequent  release  from  custody  without  charges  seventy-two  hours  later.  
4  Compl. ¶¶ 31–32.  Plaintiff argues that Garcia acted with malice when he made the false 
5  report,  “motivated  by  an  improper  purpose  stemming  from  Plaintiff’s  phone  call  to 
6  Garcia’s supervisor to complain about his aggressive behavior.”  Id. ¶ 34.   
7       To state a claim for malicious prosecution, a plaintiff must demonstrate “that the 
8  prior action (1) was commenced by or at the direction of the defendant and was pursued to 
9  a legal termination in [plaintiff’s] favor; (2) was brought without probable cause; and (3) 
10  was initiated with malice.”  Bertero v. National General Corp., 13 Cal. 3d 43, 50 (1974) 
11  (internal  citations  omitted).    Importantly,  a  “prior  action”  for  purposes  of  stating  a 
12  malicious prosecution claim must be one with “some adjudicatory involvement by a court” 
13  and not one based solely on a warrantless arrest where no charges are filed.  Van Audenhove 
14  v. Perry, 11 Cal. App. 5th 915, 925 (2017) (finding that “an arrest, without formal charges, 
15  is not a sufficient foundation for a malicious prosecution claim”); see also Holmes v. 
16  Harris, No. CV 18-3739 PSG (Ex), 2019 WL 2895632, at *4 (C.D. Cal. 2019) (finding 
17  that plaintiff could not bring a malicious prosecution claim under California law because, 
18  “although she was arrested, charges were never filed against her”).  Here, because Plaintiff 
19  was released without charges being filed, Plaintiff cannot state a claim for malicious 
20  prosecution under California law.                                         
21       Malicious prosecution can also be a cause of action under § 1983.  Plaintiff does not 
22  allege that he is bringing this claim under § 1983, unlike the rest of his § 1983 causes of 
23  action.  See generally Compl.  Construing his Complaint liberally, the Court considers 
24  malicious prosecution under § 1983 and concludes that Plaintiff has also failed to state a 
25  claim.  Plaintiff must show that Garcia “prosecuted [him] with malice and without probable 
26  cause, and that they did so for the purpose of denying [him] equal protection or another 
27  specific constitutional right.”  Freeman v. City of Santa Ana, 68 F.3d 1180, 1188 (9th Cir. 
28  1995) (citations omitted).  However, filing charges is also a requirement to state a claim 
1  under § 1983.  See Correa v. Whittier City Police Dep’t, No. 22-cv-00581-VBF (MAA), 
2  2023 WL 4409118, at *6 (C.D. Cal. March 14, 2023).                        
3       Federal Rule of Civil Procedure 15(a) “provides that leave to amend should be freely 
4  granted ‘when justice so requires.’”  Lopez v. Smith, 203 F.3d 1122, 1127 (9th Cir. 2000) 
5  (en banc) (citing Fed. R. Civ. P. 15(a)).  “Nevertheless, a district court need not grant leave 
6  to amend where the amendment would unduly prejudice the opposing party, cause undue 
7  delay, or be futile, or if the party seeking amendment has acted in bad faith.”  Nickles v. 
8  United States, 699 F. Supp. 3d 898, 925 (E.D. Cal. 2023) (citing Leadsinger, Inc. v. BMG 
9  Music Publ’g, 512 F.3d 522, 532 (9th Cir. 2008)); see also Rosati v. Igbinoso, 791 F.3d 
10  1037, 1039 (9th Cir. 2015) (“A district court should not dismiss a pro se complaint without 
11  leave to amend [pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii)] unless ‘it is absolutely clear that 
12  the deficiencies of the complaint could not be cured by amendment.’”) (quoting Akhtar v. 
13  Mesa, 698 F.3d 1202, 1212 (9th Cir. 2012)).  The Court concludes that amendment would 
14  be futile because no charges were filed.                                  
15       Accordingly, Plaintiff’s malicious prosecution claim is DISMISSED WITHOUT 
16  LEAVE TO AMEND.                                                           
17            2.  False Imprisonment                                          
18       In Claim IV, Plaintiff alleges that “Defendants”9 “intentionally, unlawfully, and 
19  without legal justification confined Plaintiff for approximately [seventy-two] hours by 
20  arresting and detaining him without probable cause.”  Compl. ¶ 52.        
21       “Under California law, the torts of false arrest and false imprisonment are not 
22  separate torts, as false arrest is ‘but one way of committing a false imprisonment.’”  
23  Watts v. Cnty. of Sacramento, 256 F.3d 886, 891 (9th Cir. 2001) (quoting Asgari v. City of 
24  Los Angeles, 15 Cal. 4th 744, 752 n.3 (1997)).  A false imprisonment claim based on an 
25  unlawful  arrest  arises  where  “there  was  an  arrest  without  process  followed  by 
26                                                                            
27                                                                            
28                                                                            
   9 Plaintiff does not specify which Defendants this claim is brought against.  See Compl. ¶¶ 51–55.  The 
1  imprisonment.”  Watts, 256 F.3d at 891 (citations omitted).  The elements of a claim for 
2  false  imprisonment  under  California  law  are:  “(1)  the  nonconsensual,  intentional 
3  confinement of a person, (2) without lawful privilege, and (3) for an appreciable period of 
4  time, however brief.”  Young v. Cnty. of Los Angeles, 655 F.3d 1156, 1169 (9th Cir. 2011) 
5  (internal quotation marks and citations omitted).                         
6       Here, Plaintiff alleges that he did not consent to be confined and that he was in 
7  custody for seventy-two hours—sufficiently alleging the first and third elements.  Compl. 
8  ¶¶ 52–53.                                                                 
9       With respect to element two, “without lawful privilege,” a law enforcement officer 
10  is not liable for false imprisonment arising out of an arrest if “[t]he arrest was lawful” or 
11  the officer “at the time of the arrest, had reasonable cause to believe the arrest was lawful.”  
12  Cal. Pen. Code § 847(b)(1).  “California courts speak of ‘reasonable cause’ and ‘probable 
13  cause’ interchangeably.”  Cornell v. City and Cnty. of San Francisco, 17 Cal. App. 5th 766, 
14  786 (2017) (declining to define, absent legislative authorization, that § 847 adds “an 
15  additional layer of protection from civil liability beyond . . . probable cause”).  Here, as 
16  discussed above, Plaintiff has sufficiently alleged that Defendant Officers arrested him 
17  without probable cause.  Therefore, Plaintiff has sufficiently alleged false imprisonment 
18  against Defendant Officers.                                               
19            3.  Intentional Infliction of Emotional Distress                
20       In  Claim  V,  Plaintiff  alleges  that  Garcia  and  Jane  Doe  2,  an  unidentified 
21  EMT/Paramedic, “engaged in a course of conduct that, taken in its totality, was extreme, 
22  outrageous, and beyond all bounds of decency tolerated in a civilized society.”  Compl. 
23  ¶ 57.                                                                     
24  ///                                                                       
25  ///                                                                       
26  ///                                                                       
27  ///                                                                       
28  ///                                                                       
1       Under California law, to state a claim for intentional infliction of emotional distress 
2  (IIED), Plaintiff must allege:                                            
3            (1) extreme and outrageous conduct by the defendant with the    
             intention of causing, or reckless disregard of the probability of 
4                                                                            
             causing, emotional distress; (2) the plaintiff's suffering severe or 
5            extreme  emotional  distress;  and  (3)  actual  and  proximate 
             causation  of  the  emotional  distress  by  [the]  defendant's 
6                                                                            
             outrageous conduct.                                             
7  Sabow v. United States, 93 F.3d 1445, 1454 (9th Cir. 1996) (citing Christensen v. Superior  
8  Court, 54 Cal. 3d 868, 903 (1991)).  “Conduct to be outrageous must be so extreme as to 
9  exceed all bounds of that usually tolerated in a civilized community.”  Miller v. Fortune  
10  Com. Corp., 223 Cal. Rptr. 3d 133, 143 (Ct. App. 2017).  There is no bright line rule for 
11  when conduct qualifies as outrageous, and it is typically a question of fact for the jury.  So 
12  v. Shin, 212 Cal. App. 4th 652, 671 (2013).  “A court may dismiss such claims as a matter 
13  of law if the conduct alleged is insufficiently outrageous, particularly where the conduct 
14  alleged amounts to ‘mere insults, indignities, threats, annoyances, petty oppressions, or 
15  other trivialities.’”   Morse  v.  Cnty.  of Merced,  No. 16-cv-142-DAD-SKO, 2016  WL 
16  3254034, at *13 (E.D. Cal. June 13, 2016) (quoting Hughes v. Pair, 46 Cal. 4th 1035, 1051 
17  (2009)).                                                                  
18                 a.  Garcia                                                 
19       Plaintiff alleges that Garcia10 “knowingly made a false report to law enforcement” 
20  that he knew or should have known “would lead to Plaintiff’s arrest, detention, and the 
21                                                                            

22                                                                            
   10 The Court notes that Garcia, at this stage, is not statutorily immune from an IIED claim.  California 
23                                                                            
   Civil Code section 47 provides that “any official proceeding authorized by law” is privileged.  The purpose 
24  of section 47 is to provide citizens with “free and open access to government agencies for the reporting of 
   suspected illegal activity.”  Williams v. Taylor, 129 Cal. App. 3d 745, 754 (1982).  However, effective 
25  January 1, 2021, the California Legislature amended § 47(b) adding an exception to the absolute privilege 
   for “any communication between a person and law enforcement agency in which the person makes a false 
26  report . . . knowing that the report is false, or with reckless disregard for the truth or falsity of the report.”  
   Cal. Civ. Code § 47(b)(5).  Therefore, taking Plaintiff’s allegations as true, Garcia is not absolutely 
27                                                                            
   privileged based on his call to law enforcement because it was intentionally false.  Further, if Garcia is 
28  found to have made the call pursuant to his duties as a city maintenance employee, he is also not statutorily 
1  foreseeable emotional distress associated with being falsely accused of a crime.”  Compl. 
2  ¶ 58.  The conduct alleged by Plaintiff goes beyond “mere insults.”  Plaintiff alleges that 
3  Garcia  intentionally  made  a  false  report  with  the  purpose  of  harassing  and  seeking 
4  retribution against Plaintiff.  Compl. ¶¶ 58–59.  Therefore, Plaintiff has sufficiently stated 
5  a claim for IIED against Garcia.  See Morse, 2016 WL 3254034, at *13 (surviving a motion 
6  to dismiss where plaintiff alleged that “individual defendants knowingly misrepresented 
7  information  in  order  to  arrest  him  and  charge  him  with  murder”  to  “exact  political 
8  retribution against plaintiff’s father”).                                 
9                 b.  Jane Doe 2                                             
10       Plaintiff alleges that, while in custody, Jane Doe 2 “acted with reckless disregard for 
11  Plaintiff’s emotional well-being by accusing him of faking his injuries.”  Compl. ¶ 60.  Jane 
12  Doe 2 is a medical professional who treated Plaintiff after his arrest.  Id. ¶ 27.  Jane Doe 2 
13  allegedly accused him of faking his injuries and compared Plaintiff to “homeless people 
14  [who] lie about having a heart attack.”  Id. ¶ 60.  The Court finds that this conduct is not 
15  sufficiently outrageous to state a claim for IIED and rather is a “mere insult.”  Morse, 2016 
16  WL 3254034, at *13.  Therefore, the IIED claim against Jane Doe 2 is DISMISSED 
17  WITH LEAVE TO AMEND.                                                      
18            4.  Negligent Infliction of Emotional Distress                  
19       In Claim VI, Plaintiff alleges that Defendant Officers “breached their duty of care to 
20  Plaintiff by negligently failing to conduct a reasonable investigation” and “refrain from 
21  using excessive force.”  Compl. ¶ 64.                                     
22                                                                            
23                                                                            
24                                                                            
25  caused by his instituting or prosecuting any judicial or administrative proceeding within the scope of his 
   employment, even if he acts maliciously and without probable cause.”  However, this immunity does not 
26  apply if the injury is “caused by acts that are merely investigatory and unconnected to the prosecution of 
   any official proceeding.”  Leon v. Cnty. of Riverside, 14 Cal. 5th 910, 926 (2023).  Therefore, because 
27                                                                            
   there were no formal charges brought against Plaintiff, Garcia is not immune if found to be acting as a 
28  public employee.  See id. (finding § 821.6 immunity does not apply in a case where no charges are ever 
1       Under California law, “[a] claim of negligent infliction of emotional distress is not 
2  an independent tort but the tort of negligence to which the traditional elements of duty, 
3  breach of duty, causation, and damages apply.”  Belen v. Ryan Seacrest Productions, LLC, 
4  65 Cal. App. 5th 1145, 1165 (2021) (internal quotation marks omitted).  In a lawful police 
5  encounter, “police officers have a duty not to use excessive force.”  Knapps v. City of 
6  Oakland, 647 F. Supp. 2d 1129, 1164 (N.D. Cal. 2009) (quoting Munoz v. City of Union 
7  City, 120 Cal. App. 4th 1077, 1101 (2004)).                               
8       Here, because Plaintiff has sufficiently alleged an excessive force claim, Plaintiff 
9  has also sufficiently alleged a negligent infliction of emotional distress (NIED) claim based 
10  on excessive force.  See J.C. v. City of Vallejo, 24-CV-1879-JAM-AC, 2025 WL 1135045, 
11  at *5 (E.D. Cal. Apr. 17, 2025) (finding that alleging excessive force was sufficient to 
12  allege NIED on the same grounds).  Further, as discussed above, Plaintiff has sufficiently 
13  alleged false arrest and false imprisonment against Defendant Officers, which creates 
14  sufficient grounds for an NIED claim to survive screening.  See Torres v. City of Los 
15  Angeles, 548 F.3d 1197, 1205 n.4 (9th Cir. 2008) (noting that the district court had 
16  dismissed a claim for negligent infliction of emotional distress because it was predicated 
17  on a claim for false arrest, which was also dismissed); see also Baker v. Rodriguez, SACV 
18  11-138-JST (PJWx), 2012 WL 137461, at *8 (C.D. Cal. Jan. 17, 2012) (holding that 
19  because plaintiff had stated a valid claim for false imprisonment, he also stated a valid 
20  claim for NIED).                                                          
21       Therefore,  Plaintiff  has  sufficiently  alleged  a  NIED  claim  against  Defendant 
22  Officers.                                                                 
23            5.  Violations of the Tom Bane Civil Rights Act—California Civil Code § 52.1 
24       In Claim VII, Plaintiff alleges that Defendant Officers and Garcia interfered with his 
25  right to be free from unreasonable seizure under the Fourth Amendment by using threats, 
26  intimidation, and coercion in violation of the Tom Bane Civil Rights Act, codified in 
27  California Civil Code § 52.1.  Compl. ¶¶ 77–80.                           
28                                                                            
1       The Bane Act provides a private cause of action for “[a]ny individual whose exercise 
2  or enjoyment of rights secured by the Constitution or laws of the United States, or of rights 
3  secured by the Constitution or laws of [California], has been interfered with” through 
4  “threat[s], intimidation, or coercion.”  Cal. Civ. Code § 52(b)–(c).  “The elements of a Bane 
5  Act claim are essentially identical to the elements of a § 1983 claim, with the added 
6  requirement that the government official had a ‘specific intent to violate’ a constitutional 
7  right.”  Hughes v. Rodriguez, 31 F.4th 1211, 1224 (9th Cir. 2022) (quoting Reese v. Cnty. 
8  of Sacramento, 888 F.3d 1030, 1043 (9th Cir. 2018)).  There are two elements to plead a 
9  Bane Act claim.  First, “there must be a ‘threat, intimidation, or coercion,’ although that 
10  element  need  not  be  ‘transactionally  independent’  from  the  underlying  constitutional 
11  violation alleged.”  Smith v. City of Marina, 709 F. Supp. 3d 926, 938 (N.D. Cal. 2024) 
12  (quoting  Reese,  888  F.3d  at  1043).    Second,  the  plaintiff  must  demonstrate  that  the 
13  defendant had a “specific intent” to commit the constitutional violation.  Reese, 888 F.3d 
14  at 1043.                                                                  
15       To show specific intent, the right at issue must be “clearly delineated and plainly 
16  applicable under the circumstances of the case,” and the defendant must have committed 
17  the act in question with the particular purpose of depriving the plaintiff of his enjoyment 
18  of that right.  Cornell, 17 Cal. App. 5th at 803.  The intent requirement is satisfied where 
19  the defendant allegedly acted with “[r]eckless disregard of the right at issue.”  Estate of 
20  Serna v. Cnty. of San Diego, No. 20-cv-2096-LAB-MSB, 2022 WL 827123, at *8 (S.D. 
21  Cal. Mar. 18, 2022) (quoting Cornell, 17 Cal. App. 5th at 804).           
22       Here, as discussed above, Plaintiff has sufficiently pled false arrest claims against 
23  Defendant Officers and Garcia.  In his false arrest claim, Plaintiff alleges that Defendant 
24  Officers “demonstrated a reckless disregard for the truth” when they failed to investigate 
25  exculpatory evidence.  Compl. ¶ 42.  “At the motion to dismiss stage . . . allegations of 
26  conduct that violates constitutional rights coupled with allegations that the conduct was 
27  done with reckless disregard for a party’s rights can be sufficient to establish specific 
28  intent.”  City of Marina, 709 F. Supp. 3d at 939.  Further, Plaintiff alleges that Garcia 
1  intentionally made a false report to cause an interference with Plaintiff’s liberty.  Compl. ¶ 
2  79.  Therefore, Plaintiff has sufficiently stated a Bane Act claim against Defendant Officers 
3  and Garcia.                                                               
4       D. Doe Defendants                                                    
5       Plaintiff names as Defendants: John Doe 1, John Doe 2, Jane Doe 1, and Jane Doe 2.  
6  “Courts  especially disfavor  ‘Doe’  pleading in  an  IFP  case because,  in  the  event  the 
7  plaintiff’s complaint alleges a plausible claim for relief, it is effectively impossible for the 
8  United States Marshal or deputy marshal to fulfill his or her duty to serve an unnamed 
9  defendant.”  Pressley v. San Diego EMT Staff, No. 24-CV-1940 JLS (MMP), 2025 WL 
10  1642436, at *4 (S.D. Cal. June 9, 2025) (first citing Fed. R. Civ. P. 4(c)(3); then citing 28 
11  U.S.C. § 1915(d)).  A plaintiff still may refer to unknown defendants as “Doe” defendants, 
12  however “he must allege specific facts showing how each particular doe defendant violated 
13  his rights.”  Id. (citing Cuda v. Employees/Contractors/Agents at or OCCC, No. 19-00084 
14  DKW-KJM, 2019 WL 2062945, at *4 (D. Haw. May 9, 2019)).                   
15       Regarding John Doe 1, John Doe 2, and Jane Doe 1, Plaintiff fails to link any 
16  violation of his rights to their conduct.  Plaintiff alleges that John Doe 1 is a National City 
17  maintenance worker who was present at Plaintiff’s arrest and that Jane Doe 1 is a plain 
18  clothes police officer who arrived after Plaintiff was arrested and placed in the police 
19  vehicle.  Compl. ¶¶ 23–24.  Plaintiff’s only allegation towards John Doe 1 and Jane Doe 1 
20  is that he told them about potential exculpatory evidence after his arrest, and they ignored 
21  him.  Id.  Further, Plaintiff alleges that John Doe 2, an internal affair detective for National 
22  City police, told Plaintiff “that he was aware of Plaintiff’s arrest and that the officers 
23  followed their training.”  Id. ¶ 91.  None of these allegations are sufficient to allege a 
24  violation of Plaintiff’s rights.  Regarding Jane Doe 2, as discussed above, Plaintiff has 
25  failed to state a claim for IIED against Jane Doe 2.                      
26       Therefore, the Doe Defendants are dismissed.  Plaintiff may amend his Complaint 
27  to allege specific conduct violating his rights by these Defendants.      
28  / / /                                                                     
1                                 CONCLUSION                                 
2       In light of the foregoing, the Court:                                
3       1.   GRANTS Plaintiff’s IFP Application (ECF No. 2);                 
4       2.   DISMISSES Claim I, malicious prosecution, against Garcia WITHOUT 
5            LEAVE TO AMEND;                                                 
6       3.   DISMISSES Claim V, intentional infliction of emotional distress, against 
7            Jane Doe 2 WITH LEAVE TO AMEND;                                 
8       4.   DISMISSES Claim IX, § 1983 Monell Claim, against the City of National 
9            City WITH LEAVE TO AMEND;                                       
10       5.   DISMISSES John Doe 1, John Doe 2, Jane Doe 1, Jane Doe 2, and the City 
11            of National City WITHOUT PREJUDICE;                             
12       6.   DIRECTS  the  Clerk  of  the  Court  to  issue  summonses  as  to  Plaintiff’s 
13            Complaint (ECF No. 1) upon Defendants Kaitlynn Norie, Sadiq Al-Mosawi, 
14            Reynaldo Velazquez, Marc Vargas, Rowdy Pauu, and Olegario Garcia, and 
15            forward them to Plaintiff along with blank U.S. Marshal Forms 285 (“USM 
16            Forms  285”).    In  addition,  the  Clerk  SHALL  PROVIDE  Plaintiff  with 
17            certified copies of this Order, a certified copy of his Complaint, and the 
18            summonses so that he may serve Defendants.  Upon receipt of this “IFP 
19            Package,” Plaintiff must complete the USM Forms 285 as completely and 
20            accurately as possible; include an address where Defendants may be served, 
21            see S.D. Cal. CivLR 4.1.c; and return them to the U.S. Marshal according to 
22            the instructions the Clerk of the Court provides in the letter accompanying his 
23            IFP Package;                                                    
24       7.   ORDERS the U.S. Marshal to serve a copy of the Complaint and summons 
25            upon Defendants Kaitlynn Norie, Sadiq Al-Mosawi, Reynaldo Velazquez, 
26            Marc Vargas, Rowdy Pauu, and Olegario Garcia as directed by Plaintiff on 
27            the USM Forms 285 provided, and to file executed waivers of personal service 
28            upon Defendants with the Clerk of the Court as soon as possible after their 
1               return.  Should any Defendant fail to return the U.S.  Marshal’s request for 
2               waiver of personal service within 90 days, the U.S. Marshal shall instead file 
3               the completed USM Form 285 Process Receipt and Return with the Clerk of 
4               the Court; include the date the summons, Complaint, and request for waiver 
5               were  mailed  to  that  Defendant;  and  indicate  why  service  upon  the  party 
6               remains unexecuted.  All costs of said service will be advanced by the United 
7               States; however, if a Defendant located within the United States fails, without 
8               good cause, to sign and return the waiver requested by the U.S. Marshal on 
9               Plaintiff's behalf,  the  Court will  impose upon the  Defendant any  expenses 
10               later incurred in making personal service.  See 28 U.S.C.  §  1915(d); Fed. R. 
1]               Civ. P. 4(c)(3); 
12         8.     ORDERS Defendants, once they have been served, to respond to Plaintiffs 
13               Complaint, and any subsequent pleading he may file in this matter in which 
14               they  are  named  as  parties,  within  the  time  provided  by  the  applicable 
15               provisions of Federal Rules of Civil Procedure 12(a) and 15(a)(3); and 
16         9.     ORDERS Plaintiff, after service has been effected by the U.S.  Marshal, to 
17               serve  upon  Defendants—or,  if appearances  have been  entered by  counsel, 
18               upon Defendants’ counsel—a copy of every further pleading, motion, or other 
19               document submitted for the Court’s consideration pursuant to Federal Rule of 
20               Civil Procedure 5(b).  Plaintiff must include with every original document he 
21               seeks to  file with the Clerk of the Court a certificate  stating the manner in 
22               which a  true and correct copy of that document was served on Defendants or 
23               their counsel  and the date of that  service.  See  S.D.  Cal.  CivLR 5.2.  Any 
24               document received by the Court that has not been properly filed with the Clerk 
25               of the Court, or that fails to include a  certificate of service upon Defendants, 
26               may be disregarded. 
27         IT IS SO ORDERED.                       (ee 
28    Dated:  November 17,  2025                            on. Janis E. Sammartino 
                        ,                                United States District  Judge 

Case Information

Court
S.D. Cal.
Decision Date
November 17, 2025
Status
Precedential
Eloy Mascorro v. The City of National City, Olegario Garcia, Kaitlynn Norie, Sadiq Al-Mosawi, Reynaldo Velazquez, Marc Vargas, Rowdy Pauu, Jane Does 1–2, and John Does 1–2 | Tortwell