Hernandez v. County of Monterey
306 F.R.D. 279
N.D. Cal.2015Background
- This is an order from United States Magistrate Judge Growal addressing motions to strike affirmative defenses in a class action concerning Monterey County Jail policies and disability-access practices.
- Plaintiffs challenge nine defenses by California Forensic Medical Group (CFMG) and sixteen defenses by County of Monterey, plus the County’s jury-trial demand.
- The court applies Twombly/Iqbal pleading standards to determine whether defenses provide fair notice and plausibility.
- CFMG and County amended answers after initial deficiencies were identified; plaintiffs filed motions to strike the challenged defenses.
- The court grants the motions to strike and permits amendment of defenses with a May 14, 2015 deadline.
- The ruling clarifies that the defenses must meet heightened pleading standards and provide identifiable factual bases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CFMG’s first defense is properly pled | CFMG’s language is equivocal and lacks identifiable facts. | CFMG asserted a limitations-based defense to preserve facts yet lacks detail. | CFMG’s first defense struck. |
| Whether CFMG’s other listed defenses meet fair notice under Twombly/Iqbal | Defenses are implausible or fail to plead facts. | Defenses sufficiently pleaded under pre-Twombly standard (argues notice). | Multiple defenses struck for lack of factual support; fourth through ninth defenses struck. |
| Whether County’s defenses are proper affirmative defenses | County fails to allege proper independent grounds; many are denials or improper immunities. | County contends defenses provide fair notice and legal grounds. | Most of County’s defenses stricken as improper affirmative defenses; some are invalid as they negate elements rather than plead facts. |
| Whether the defense of equitable estoppel/standing etc. is adequate post-Twombly | Defenses lack necessary facts supporting elements. | Defenses rely on pre-Twombly precedents. | Equitable estoppel and standing defenses stricken for failure to plead elements. |
| Whether the County’s jury-trial demand is proper given the relief sought | Plaintiffs seek equitable relief only; jury trial not applicable. | Monetary relief would justify a jury trial. | Jury-trial demand stricken; relief sought is equitable. |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (heightened pleading requires non-conclusory factual support)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (Twombly applies to all civil actions; pleadings must show plausibility)
- Quintana v. Baca, 233 F.R.D. 562 (C.D. Cal. 2005) (strikes boilerplate and improper standing defenses as not proper affirmative defenses)
- Barnes v. AT&T Pension Ben. Plan-Nonbargained Program, 718 F. Supp. 2d 1167 (N.D. Cal. 2010) (requires identifiable facts to plausibly support affirmative defenses)
- Monell v. New York City Dept. of Social Services, 436 U.S. 658 (U.S. 1978) (state immunities do not immunize federal civil rights claims)