Williams v. City of Sacramento

No. 2:24-cv-0768-TLN-JDP (PS) (E.D. Cal. May 1, 2025) · United States District Court for the Eastern District of California · May 1, 2025 · No. 2:24-cv-0768-TLN-JDP (PS)

Summary

The document is a magistrate judge’s findings and recommendations in a Section 1983 action brought by Donta Williams against the City of Sacramento and other municipal defendants. The court recommends dismissal without leave to amend because the second amended complaint failed to identify a municipal policy, custom, or practice causing the alleged detention and destruction of personal property. The recommendations were issued under 28 U.S.C. § 636(b)(1), with fourteen days allowed for objections.

Holdings

  1. A plaintiff suing municipal entities under § 1983 must identify a specific policy, custom, or practice of the entity and plausibly explain how it caused the alleged constitutional injury. Because the second amended complaint did not do so, it failed to state a claim.
  2. Further leave to amend should be denied where the plaintiff has repeatedly failed to cure a previously identified pleading deficiency.

Questions Presented

  1. Whether the second amended complaint stated a plausible § 1983 claim against municipal defendants without identifying a policy, custom, or practice that caused the alleged constitutional injuries.
  2. Whether plaintiff should be granted further leave to amend after failing to cure the same pleading deficiency in three complaints.

Disposition

other

Cases Cited (13)

  • Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)(followed)
  • Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009)(followed)
  • Kobold v. Good Samaritan Regional Medical Center, 832 F.3d 1024, 1038 (9th Cir. 2016)(followed)
  • Nagrampa v. MailCoups, Inc., 469 F.3d 1257, 1264 n.2 (9th Cir. 2006) (en banc)(followed)
  • Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam)(followed)
  • Hayes v. Idaho Correctional Center, 849 F.3d 1204, 1208 (9th Cir. 2017)(followed)
  • Bruns v. National Credit Union Administration, 122 F.3d 1251, 1257 (9th Cir. 1997)(followed)
  • Ivey v. Board of Regents, 673 F.2d 266, 268 (9th Cir. 1982)(followed)
  • Sadoski v. Mosley, 435 F.3d 1076, 1079-80 (9th Cir. 2006)(followed)
  • Buckley v. County of San Mateo, No. 16-cv-07314-JD, 2018 U.S. Dist. LEXIS 104370, at *8 (N.D. Cal. June 21, 2018)(followed)

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