Floyd v. Singh

Summary

The United States District Court for the Northern District of California grants defendants’ motion to dismiss in part in this pro se civil-rights action arising from Floyd’s arrest and treatment at a gym. The court dismisses the First, Second, and Fourth Amendment claims with leave to amend for failure to link specific defendants to specific conduct and dismisses the Fourteenth Amendment excessive-force claims and state-law emotional-distress claims without leave to amend. An amended complaint may be filed by September 5, 2025.

Holdings

1. Claims against the officers in their official capacities were dismissed because Floyd did not allege that a City of Hayward policy, ordinance, regulation, or officially adopted decision caused his injuries.
2. The first and second § 1983 claims, alleging an unlawful search of Floyd's cell phone and an unlawful seizure of his person, were dismissed with leave to amend because the complaint did not identify which defendant engaged in which conduct.
3. The fourth claim was dismissed with leave to amend because the gym manager was not a defendant and the complaint did not allege which officer caused or permitted the alleged seizure of Floyd's possessions.
4. The third and fifth claims were dismissed without leave to amend because excessive-force claims arising during an arrest, investigatory stop, or other seizure of a free citizen are analyzed under the Fourth Amendment, not the Fourteenth Amendment.
5. The sixth and seventh claims for negligent and intentional infliction of emotional distress were dismissed without leave to amend because Floyd did not allege compliance with the California Government Claims Act and did not oppose dismissal.

Questions Presented

1. Whether the claims against the officers in their official capacities stated a claim under § 1983 absent allegations of a Hayward policy, ordinance, regulation, or decision causing the alleged injuries.
2. Whether Floyd adequately pleaded personal participation by each defendant in the alleged Fourth Amendment search and seizure claims.
3. Whether the claim concerning collection of Floyd's personal items adequately alleged conduct by the named defendants.
4. Whether excessive-force claims arising during an arrest or seizure may be pleaded under the Fourteenth Amendment rather than the Fourth Amendment.
5. Whether Floyd's California emotional-distress claims were barred by failure to comply with the California Government Claims Act and by abandonment of the claims through failure to oppose dismissal.

Disposition

other