Cano-Diaz v. City of Leeds
2012 U.S. Dist. LEXIS 107590
N.D. Ala.2012Background
- Eleven original plaintiffs; court required repleader and a separate-claim pleading for each plaintiff against each defendant.
- Amended Complaint filed May 14, 2012; severed and narrowed to Cano-Diaz against Leeds, in a separate case.
- Cano-Diaz, a 22-year-old Hispanic woman, alleged Leeds police implemented a policy of suspicionless stops and frisks.
- Specific stop on February 21, 2012 cited for crossing fog line; arrested and charged with driving without a license, failure to maintain lane; claim pretextual based on ethnicity and immigration enforcement.
- Cano-Diaz asserted Fourth and Fourteenth Amendment §1983 claims, Title VI disparate impact claim, and requests for remedial relief and damages; putative class allegations were tied to the broader case.
- District court granted the motion to dismiss, applying Younger abstention and Heck bar, and dismissed Title VI with prejudice; other claims dismissed without prejudice; case overall dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Fourth Amendment claim is barred | Cano-Diaz | Leeds | Yes, dismissed under Younger and Heck. |
| Whether Fourteenth Amendment claim is barred | Cano-Diaz | Leeds | Yes, dismissed under Younger and Heck. |
| Whether Title VI claim is cognizable | Cano-Diaz | Leeds | No private right to enforce disparate impact; dismissed with prejudice. |
| Whether damages/remedial and class claims survive | Cano-Diaz | Leeds | All dependent on cognizable underlying claims; dismissed. |
Key Cases Cited
- Younger v. Harris, 401 U.S. 37 (1971) (abstention when state proceedings are ongoing)
- Green v. Jefferson County Comm’n, 563 F.3d 1243 (11th Cir.2009) (abstention applies to state proceedings and constitutional challenges)
- Perez v. Ledesma, 401 U.S. 82 (1971) (state proceedings provide adequate forum for constitutional defenses)
- Heck v. Humphrey, 512 U.S. 477 (1994) (damages claims relating to convictions barred unless conviction invalidated)
- Wallace v. Kato, 549 U.S. 384 (2007) (timing of when to disallow claims pending criminal outcomes; stay often appropriate)
- Alexander v. Sandoval, 532 U.S. 275 (2001) (no private right of action to enforce disparate impact regulations)