Hahn v. Carlsbad, City of
3:15-cv-02007
S.D. Cal.Jun 16, 2017Background
- On July 31, 2013 Officer Kenyatte Valentine began to impound a car for expired tags; plaintiff Cindy Hahn approached and an exchange occurred; versions of who was abusive/disorderly differ.
- Hahn got into a friend’s SUV; Valentine stopped the SUV for a seatbelt violation. Hahn exited, moved around the vehicle to retrieve documents, and an arrest occurred. Parties dispute compliance with officers’ orders.
- Valentine grabbed Hahn’s wrists and swept her legs, causing her to fall; backup Officer Jody Knisley arrived and used strikes/kneeing during restraint per differing accounts. Corporal Galanos was present and supervised scene control. Officers Karches and Seapker arrived after custody.
- Hahn was prosecuted in state court; the preliminary hearing produced a finding sufficient to bind her over on resisting-related charges.
- Hahn sued under 42 U.S.C. § 1983 (unlawful arrest, malicious prosecution, excessive force), Monell, California Bane Act, negligence, and battery; defendants moved for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether probable cause for arrest/malicious prosecution exists (collateral estoppel) | Hahn says officer withheld material evidence at prelim, so probable cause should be relitigated | State court bound her over; collateral estoppel applies unless officer fabricated/concealed evidence | Court: collateral estoppel bars relitigation — no evidence of fabrication beyond conflicting accounts; summary judgment for defendants on unlawful arrest and malicious prosecution claims |
| Whether Officers used excessive force (Fourth Amendment) | Hahn contends she complied, posed no threat, and was thrown/struck/kneed unnecessarily | Officers say Hahn resisted, evaded, and force used was reasonable to effect arrest | Court: genuine disputes of material fact exist as to Valentine and Knisley; excessive-force claims survive summary judgment |
| Qualified immunity for Valentine and Knisley | Officers assert their actions were reasonable and not clearly unlawful | Hahn argues force was excessive and clearly proscribed in similar circumstances | Court: factual disputes preclude qualified immunity; right to be free from unnecessary striking/kneeing was clearly established |
| Monell and other municipal theories (failure to train, ratification, custom) | Hahn alleges deficient training, ratification, customs (retaliation, arrests without cause, failure to investigate) | City points to training, policies (Policy 300), POST training, and lack of evidence of customs or final policymaker ratification | Court: grants summary judgment to City on Monell claims (no deliberate indifference, no ratification, no established custom) |
Key Cases Cited
- Graham v. Connor, 490 U.S. 386 (1989) (Fourth Amendment reasonableness standard for use of force)
- City of Canton v. Harris, 489 U.S. 378 (1989) (municipal liability for failure to train requires deliberate indifference)
- Monell v. Dept. of Social Servs. of City of N.Y., 436 U.S. 658 (1978) (municipal liability only for official policy or custom)
- Awabdy v. City of Adelanto, 368 F.3d 1062 (9th Cir. 2004) (collateral estoppel and relitigation of probable cause; officer fabrication exception)
- Young v. County of Los Angeles, 655 F.3d 1156 (9th Cir. 2011) (excessive force principles; significant force against suspect of minor crime who posed no threat could be excessive)
- Anderson v. Creighton, 483 U.S. 635 (1987) (qualified immunity framework: clearly established law)
- Dubner v. City & County of San Francisco, 266 F.3d 959 (9th Cir. 2001) (false arrest claim requires absence of probable cause)
- Palmer v. Sanderson, 9 F.3d 1433 (9th Cir. 1993) (excessive force prohibition clearly established)