Aaron Raiser v. Los Angeles County Sheriff, 698 F. App'x 415

Pro se plaintiff Aaron Raiser sued under 42 U.S.C. § 1983, including a Monell claim against a municipality, asserting constitutional violations by municipal actors.
The district court granted summary judgment for defendants, concluding Raiser failed to show a municipal policy, custom, or final policymaker decision caused a constitutional deprivation.
The district court dismissed Raiser’s claims against unnamed Doe defendants without prejudice for failure to effect proper service after notice under Federal Rule of Civil Procedure 4(m).
The district court denied Raiser’s discovery motions prior to ruling on summary judgment; the court found he had not shown the specific facts he hoped to discover would preclude summary judgment.
The district court denied Raiser’s motion to recuse the magistrate judge; the court found no reasonable question as to the magistrate’s impartiality.
Raiser appealed; the Ninth Circuit reviewed the summary-judgment decision de novo and affirmed in an unpublished disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Monell liability: whether a municipal policy/custom/final policymaker caused a constitutional violation	Raiser argued municipal policy, practice, or custom caused his injury	Defendants argued Raiser failed to identify any official policy, long‑standing practice, or final policymaker decision causing a constitutional violation	Affirmed — Raiser failed to raise a genuine dispute of material fact on Monell causation
Service on Doe defendants under Rule 4(m)	Raiser contended claims against Doe defendants should proceed	Defendants (and district court) argued Raiser failed to properly identify and serve Doe defendants after notice and opportunity	Affirmed — dismissal without prejudice appropriate for failure to effect timely service after notice
Denial of discovery before summary judgment	Raiser sought discovery to oppose summary judgment and claimed the court should allow it	Defendants argued Raiser did not show the specific facts he hoped to discover or that such discovery would preclude summary judgment	Affirmed — Raiser failed to proffer sufficient facts showing sought evidence existed and would prevent summary judgment
Recusal of magistrate judge	Raiser moved to recuse, alleging partiality	Defendants argued no facts suggested the magistrate's impartiality could reasonably be questioned	Affirmed — denial proper; recusal standard not met

Monell v. Department of Social Services, 436 U.S. 658 (1978) (municipal liability under § 1983 requires an official policy, custom, or final policymaker decision)
Doe v. Abbott Labs., 571 F.3d 930 (9th Cir. 2009) (standard of de novo review on appeal)
Ellins v. City of Sierra Madre, 710 F.3d 1049 (9th Cir. 2013) (municipal § 1983 liability arises from policy, custom, or final policymaker)
Thompson v. Maldonado, 309 F.3d 107 (9th Cir. 2002) (standard for reviewing dismissals for failure to serve)
Chance v. Pac‑Tel Teletrac Inc., 242 F.3d 1151 (9th Cir. 2001) (plaintiff must show discovered facts likely to preclude summary judgment)
Tatum v. City & County of San Francisco, 441 F.3d 1090 (9th Cir. 2006) (standard for evaluating motions to continue discovery to oppose summary judgment)
Jorgensen v. Cassiday, 320 F.3d 906 (9th Cir. 2003) (standard for review of recusal motions)
United States v. Hernandez, 109 F.3d 1450 (9th Cir. 1997) (substantive standard for evaluating judicial recusal)