Knight v. Richardson Bay Regional Agency, 637 F.Supp.3d 789

Plaintiff Daniel Knight sought a temporary restraining order to prevent the Richardson Bay Regional Agency (RBRA) and its officials from seizing and disposing of his vessel, the Coronado, which RBRA labeled “marine debris” under Cal. Harb. & Nav. Code §§ 550–551.
Knight alleges he has lived aboard the Coronado for ~25 years, the vessel is seaworthy and has value, and seizure would render him homeless given limited income and health issues; RBRA disputes residence and says the boat has debris and rarely moves.
RBRA posted a 10‑day removal notice, offered Knight a cash “buy‑back” option, and contends removal is part of enforcement and environmental protection in Richardson Bay.
Knight brings claims under § 1983 (Fourth and Fourteenth Amendments), the Takings Clause (Fifth Amendment), and various state and federal causes of action, and seeks injunctive relief and damages.
The Court found serious questions on the merits of Knight’s substantive due process, Fourth Amendment seizure, and Fifth Amendment takings claims, and concluded the balance of hardships tips sharply in Knight’s favor; it granted a TRO preserving the status quo and set an expedited schedule for a preliminary injunction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Coronado qualifies as “marine debris” under CHNC §§ 550–551	Coronado is seaworthy, moves, has value, and therefore is not marine debris	RBRA’s survey/inspection shows unseaworthy condition and debris; statutory authority to remove marine debris	Court: factual dispute; serious questions going to the merits — TRO appropriate pending further proceedings
Whether towing/seizing the vessel would violate the Fourth Amendment	Coronado is Plaintiff’s home; seizure/towing would be an unreasonable seizure of property/home	Seizure is authorized by CHNC as enforcement of environmental/harbor rules	Court: serious questions about reasonableness and lack of pre‑seizure hearing; TRO warranted
Whether seizure without just compensation violates the Fifth Amendment Takings Clause	Physical taking without adequate or unconditional compensation (buy‑back terms problematic)	RBRA offered buy‑back compensation, negating a per se taking	Court: serious questions exist about adequacy/conditioning of compensation; TRO warranted
Whether irreparable harm and balance of equities favor injunctive relief	Eviction would likely render Knight homeless and harm his health; constitutional infringements are irreparable	RBRA cites public/environmental interest in removing debris but does not show immediate irreparable public harm	Court: Plaintiff likely to suffer irreparable harm; balance of hardships tips sharply to Knight; TRO issued

Porretti v. Dzurenda, 11 F.4th 1037 (9th Cir.) (sliding‑scale/serious‑questions standard for injunctions applied)
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (standards for preliminary injunctions and irreparable harm)
Doe v. San Diego Unified Sch. Dist., 19 F.4th 1173 (9th Cir.) (serious‑questions formulation cited)
All. for the Wild Rockies v. Cottrell, 632 F.3d 1127 (9th Cir.) (injunction standard and balance of hardships/public interest analysis)
Soldal v. Cook County, Ill., 506 U.S. 56 (1992) (seizure of a home/mobile dwelling implicates Fourth Amendment)
Knick v. Township of Scott, Pa., 139 S. Ct. 2162 (2019) (takings claim available in federal court when government takes property without compensation)
Cedar Point Nursery v. Hassid, 141 S. Ct. 2063 (2021) (physical appropriation is per se taking requiring compensation)
Corales v. Bennett, 567 F.3d 554 (9th Cir.) (substantive due process: ‘‘shocks the conscience’’ standard)
Stuhlbarg Int’l Sales Co. v. John D. Brush & Co., 240 F.3d 832 (9th Cir.) (TROs subject to same standard as preliminary injunctions)
Granny Goose Foods, Inc. v. Teamsters, 415 U.S. 423 (1974) (TRO limited to preserving status quo pending hearing)