Gary Easley v. County of Santa Clara, 702 F. App'x 552

Background

On December 23, 2008, Deputy Gerard Wallace encountered Gary Easley in a vehicle parked on private property where burglaries had been reported; Easley did not know the property owner and admitted a recent methamphetamine possession charge.
Wallace observed signs of drug impairment (nervousness, rapid speech, dilated unreactive pupils, trembling eyelids, rapid pulse, hot skin) and briefly detained Easley for investigation.
Wallace conducted a field test and then arrested Easley for suspected methamphetamine influence under Cal. Health & Safety Code § 11550.
Wallace ordered Easley’s vehicle impounded under Cal. Veh. Code § 22651(h)(1) because it was on private property and Easley lacked permission or knowledge of the owner.
A non‑consensual blood draw was taken; Easley challenged the warrantless blood draw and asserted various § 1983 claims (false arrest, illegal search/seizure, Monell failure‑to‑train, intentional infliction of emotional distress, unlawful vehicle seizure) and related state claims.
The district court granted summary judgment to defendants; the Ninth Circuit affirmed in all respects, including qualified immunity for the blood draw claim and denial of Monell and state‑law claims.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Lawful investigative stop	Easley contends stop was unlawful	Wallace had articulable suspicion (vehicle on private property, burglary reports, observed impairment, admission of prior meth arrest)	Stop was lawful; reasonable suspicion supported brief detention (Sokolow standard)
Probable cause for arrest	Easley disputes basis for arrest for drug intoxication	Observations and field test gave probable cause for §11550 arrest	Probable cause existed based on totality of facts (Sialoi)
Vehicle impoundment	Easley challenges seizure/impound	Vehicle on private property, no owner permission; impound served caretaking function under Cal. Veh. Code §22651(h)(1)	Impound lawful; community‑caretaking and statutory authority supported removal (Caseres)
Warrantless blood draw / Fourth Amendment	Easley argues warrant required for non‑consensual blood draw	Exigent‑circumstances doctrine and existing precedent allow warrantless blood tests in some drug cases; Wallace could not know time window to obtain warrant	Qualified immunity granted because law was not "clearly established" that a warrant was required under these facts (Pearson; Schmerber; Birchfield; McNeely)
Monell failure‑to‑train / §1983 against County	Easley says County failed to train/policy caused violation	No underlying constitutional violation established; no pattern of similar misconduct; Wallace followed County policy limiting warrantless draws	Summary judgment proper: no Monell liability shown (Long)
State negligent supervision/claim presentation	Easley asserts state tort claim against County	County argues tort claim untimely under Cal. Gov. Code §911.2(a)	Claim barred as untimely; notice filed ~18 months after incident, beyond six‑month requirement

Key Cases Cited

United States v. Sokolow, 490 U.S. 1 (articulable suspicion standard for investigatory stops)
Schmerber v. California, 384 U.S. 757 (exigent‑circumstances exception permitting warrantless blood test in some cases)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework / prongs)
Birchfield v. North Dakota, 136 S. Ct. 2160 (warrant vs. exigency analysis for blood tests)
Missouri v. McNeely, 133 S. Ct. 1552 (exigency depends on circumstances; cannot automatically bypass warrant requirement)
Sialoi v. San Diego, 823 F.3d 1223 (probable cause assessed by totality of facts)
United States v. Caseres, 533 F.3d 1064 (vehicle impound and community caretaking function under §22651)
Anderson v. Creighton, 483 U.S. 635 (definition of clearly established law for qualified immunity)
Long v. County of Los Angeles, 442 F.3d 1178 (Monell failure‑to‑train requires pattern or highly predictable consequences)