Leonides Enriquez v. City of Long Beach
2:23-cv-06464
C.D. Cal.May 5, 2025Background
- Plaintiff Leonides Enriquez filed a § 1983 civil rights lawsuit against the City of Long Beach and Officers Lizardo, Mays, Costin, and Nogales after being shot during a police encounter following an armed robbery and vehicle pursuit.
- On August 8, 2021, after a reported armed robbery and vehicle pursuit, the officers confronted Enriquez, who matched the suspect's description and was believed to be armed.
- During the encounter, Enriquez was ordered multiple times to keep his hands visible and on the police vehicle; he at times failed to comply but did not attempt to flee or actively resist arrest.
- Officers Mays and Lizardo shot Enriquez, who claims he was attempting to comply with commands to get on his knees; officers maintain he was reaching for his gun.
- Enriquez asserted several claims, but at summary judgment, only excessive force claims against Officers Mays and Lizardo and municipal liability/failure to train claims against the City remained.
- The court granted summary judgment on all but the excessive force claim against Officers Mays and Lizardo, which will proceed to trial due to disputed facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (Mays/Lizardo) | Shooting was unreasonable; he wasn't a threat when shot | Force was reasonable given events and commands | Denied summary judgment; dispute of material fact remains |
| Qualified immunity (Mays/Lizardo) | Clearly established right not to be shot when not threatening | Not clearly established law for these facts | Not entitled to qualified immunity; law was clearly established |
| Excessive force (Costin/Nogales) | Costin liable as integral participant | Not integral participants; no clear law applies | Granted summary judgment; no clearly established violation |
| Failure to train (City) | City had inadequate officer training | No evidence of widespread training deficiencies | Granted summary judgment; insufficient evidence of pattern |
| Policy/custom claim (City) | (No opposition/argument pressed) | No evidence of unconstitutional policy or custom | Granted summary judgment; claim abandoned/unsupported |
Key Cases Cited
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard on genuine issues of material fact)
- Graham v. Connor, 490 U.S. 386 (articulates reasonableness standard for excessive force under the Fourth Amendment)
- Ashcroft v. al-Kidd, 563 U.S. 731 (clearly established law must be particularized to the facts)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity two-prong analysis)
- City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train requires deliberate indifference)