Juan Velazquez v. James Logan, 16-15485

Velazquez sued Maricopa County, a county official (Logan), and two private employees (Hardy, McCloskey) under 42 U.S.C. § 1983 and state law after they withheld a storage-locker key and access code pending a court order.
Hardy and McCloskey, non-state employees, acted at Logan’s direction in withholding the key; Logan was a state actor.
The district court granted summary judgment to defendants and denied Velazquez’s cross-motion; Velazquez appealed.
The district court had applied the Rooker–Feldman doctrine to dismiss federal claims as a de facto state-court appeal; the Ninth Circuit reviewed that ruling and the grant of summary judgment de novo.
The Ninth Circuit held Rooker–Feldman did not apply because Velazquez challenged defendants’ conduct and interpretation of a state-court order, not the state-court judgment itself.
On the merits, the court concluded no Fourth or Fourteenth Amendment violation: Hardy and McCloskey’s conduct lacked governmental investigatory intent; Logan’s administrative decision was objectively reasonable; and an adequate post-deprivation remedy was available when the state superior court later ordered return of the key and code.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Rooker–Feldman	Velazquez argued federal court could hear his constitutional claims despite related state-court proceedings.	Defendants argued plaintiff’s claims were a forbidden de facto appeal of the state court decision.	Rooker–Feldman does not bar the suit because plaintiff challenges defendants’ conduct/interpretation, not the state-court judgment.
§ 1983 liability for private employees	Hardy and McCloskey were liable as willful participants in joint action with the state.	Defendants argued private employees were not state actors.	Hardy and McCloskey could be treated as state actors because they followed Logan’s instructions.
Fourth Amendment (unreasonable seizure/search)	Withholding key/code unlawfully deprived access to property.	Defendants argued no governmental investigatory intent by Hardy/McCloskey and Logan’s administrative actions were reasonable.	No Fourth Amendment violation: private employees lacked investigatory intent; Logan’s administrative withholding was objectively reasonable.
Fourteenth Amendment due process	Plaintiff argued deprivation of property without due process.	Defendants argued adequate post-deprivation remedy existed and actions were not conscience-shocking.	No procedural or substantive due process violation: state-court order restoring access provided adequate post-deprivation remedy; actions were not arbitrary or conscience-shocking.

Bell v. City of Boise, 709 F.3d 890 (9th Cir. 2013) (Rooker–Feldman framework for distinguishing forbidden de facto appeals)
Morrison v. City of New York, 591 F.3d 109 (2d Cir. 2010) (declining Rooker–Feldman where dispute centered on competing interpretations of an ambiguous state-court order)
Kirtley v. Rainey, 326 F.3d 1088 (9th Cir. 2003) (private parties may be § 1983 defendants when willful participants in joint action with the state)
Collins v. Womancare, 878 F.2d 1145 (9th Cir. 1989) (standards for joint action liability under § 1983)
United States v. Attson, 900 F.2d 1427 (9th Cir. 1990) (governmental intent required to convert private conduct into a Fourth Amendment search/seizure)
San Jose Charter of Hells Angels Motorcycle Club v. City of San Jose, 402 F.3d 962 (9th Cir. 2005) (balancing degree of intrusion against government justification)
Hudson v. Palmer, 468 U.S. 517 (1984) (adequate post-deprivation remedy negates procedural due process claim)
FDIC v. Henderson, 940 F.2d 465 (9th Cir. 1991) (substantive due process requires deprivation that is clearly arbitrary and unreasonable)
County of Sacramento v. Lewis, 523 U.S. 833 (1998) (substantive due process standard: conduct that shocks the conscience)