Shale Well v. County of Alameda

Summary

The United States District Court for the Northern District of California denied the County of Alameda’s motion under Federal Rule of Civil Procedure 12(f) to strike the plaintiff’s requests for attorneys’ fees and injunctive relief. The court held that Rule 12(f) is not an appropriate vehicle to challenge a request for a particular form of relief and alternatively concluded that the issues were better addressed at a later stage. The order did not decide the County’s separate Rule 12(b)(6) motion to dismiss.

Holdings

1. Rule 12(f) is not an appropriate vehicle to strike a request for a particular form of relief, including requests for attorney fees or injunctive relief, and does not authorize dismissal of a damages claim merely because the requested relief is legally unavailable.
2. Even if the requests were not legally improper under Rule 12(f), the court would deny the motion in its discretion because the attorney-fee issue could change if Well later retained counsel and the injunctive-relief issues required factual development.

Questions Presented

1. Whether Rule 12(f) authorizes the court to strike Well's requests for attorney fees and injunctive relief from the complaint.
2. Whether the County established grounds, in the court's discretion, to strike those requests at the early pleading stage.

Disposition

other