Deepa Patel v. City of Stanton
2:24-cv-06998
| C.D. Cal. | May 19, 2025Background
- Plaintiffs Ahir and Megha Hospitality LLC operated a motel in Stanton, CA under a business license; Patel and California One Hospitality LLC owned and leased the motel but were plaintiffs only in a related, now-dismissed action.
- The City of Stanton issued an administrative citation and ultimately revoked the motel's conditional use permit, allegedly without notifying Ahir and Megha Hospitality LLC, who held the business license.
- Plaintiffs claimed this lack of notice deprived them of procedural due process rights under the Fourteenth Amendment, and subsequently their business license was also revoked after a hearing.
- At the business license revocation hearing, plaintiffs attended and presented arguments, but objected that the hearing officer (Palacios) was City-appointed and potentially biased.
- The federal court had previously dismissed similar claims with prejudice against Patel and California One Hospitality LLC, permitting amendment only for Ahir and Megha Hospitality LLC as to Fourteenth Amendment concerns.
- Plaintiffs also sought state writ relief under California law, challenging both notice and fairness of the City's actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to Challenge Permit and Citation Revocation | Plaintiffs had a direct business interest affected | Plaintiffs lacked standing—they were not permittees | No standing for Ahir/Megha re permit/citation |
| Procedural Due Process for Business License Revocation | Lack of fair hearing due to biased officer selection | Plaintiffs got notice, hearing, opportunity to object | Due process satisfied; no claim stated |
| Alleged Hearing Officer Bias under Haas v. San Bernardino | Haas applies: City-appointed, paid officer is biased | No facts showing financial bias; Haas nonbinding | Claim inadequately pled and not federally controlling; dismissed |
| Protected Property Interest in Business License | License is a protected property interest | City Ordinance grants discretionary revocation power | No protectable property interest found |
| State Law Writ Claim | Relief to compel reversal of City action | Court should not exercise supplemental jurisdiction | Court declines supplemental jurisdiction |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for plausibility in federal court)
- Ashcroft v. Iqbal, 556 U.S. 662 (district court must disregard conclusory allegations at motion to dismiss)
- Bd. of Regents of State Colls. v. Roth, 408 U.S. 564 (defining property interest under due process)
- Town of Castle Rock v. Gonzales, 545 U.S. 748 (no entitlement when government retains discretion)
- Mullane v. Cent. Hanover Bank & Tr. Co., 339 U.S. 306 (due process requires notice and opportunity to be heard)
- Wedges/Ledges of Cal., Inc. v. City of Phoenix, 24 F.3d 56 (property interest analysis under state law and due process)
- Kraft v. Jacka, 872 F.2d 862 (no property interest where broad government discretion to grant/dismiss license)
- Lujan v. Defs. of Wildlife, 504 U.S. 555 (federal standing requirements for injury in fact)