Lesher v. City of Anderson, 2:21-cv-00386

Background:

On Aug. 13, 2019, Lesher was interacting on her apartment porch when Anderson PD officers responded to a noise complaint; officers alleged a dog bite, Lesher confronted officers about their conduct, and officers then used force, arrested and booked her.
Lesher alleges she complied with commands, sustained physical injuries (forearm, clavicle, finger) and property damage, and was criminally prosecuted on misdemeanor obstruction charges but acquitted at trial.
Lesher sued the City of Anderson and officers under 42 U.S.C. § 1983 and state claims; the SAC asserted Monell theories against the City for (1) unconstitutional policy/custom, (2) ratification, and (3) failure to train/supervise.
The City moved to dismiss the fourth cause of action (Monell municipal liability) for failure to plead facts supporting a municipal policy, ratification, or deficient training causally linked to Lesher’s injuries.
The SAC relied on four prior lawsuits against APD officers and generalized allegations of deficient policies/practices; the court took judicial notice of those dockets and evaluated similarity, number, timing, and dispositions.
The court dismissed the Monell claim with prejudice (no further leave to amend), holding Lesher’s allegations were conclusory or insufficient to plead a custom, ratification, or a failure-to-train claim causally connected to the constitutional deprivation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether SAC adequately pleads Monell liability based on an unconstitutional policy or custom	Lesher alleges multiple generalized customs/policies and cites four prior lawsuits showing a pattern	City argues the allegations are conclusory, prior cases dissimilar or unresolved, and do not show a longstanding practice	Dismissed — generalized policy allegations and the cited prior suits (mostly dissimilar/settled or pending) fail to plausibly allege a widespread, well-settled custom
Whether SAC pleads municipal liability by ratification	Lesher points to prior suits and continued employment/promotions of officers as implicit approval	City contends no factual allegations identify authorized policymakers who expressly approved the officers’ conduct	Dismissed — no factual allegation showing policymaker approval or deliberate endorsement of the specific actions
Whether SAC pleads Monell failure-to-train claim	Lesher ties failure-to-train to the same alleged customs/policies and prior incidents	City contends there are no factual allegations about the training program, deliberate indifference, or causation	Dismissed — no factual allegations describing training deficiencies, deliberate indifference, or causal link to Lesher’s injury
Whether plaintiff should get further leave to amend	Lesher requested limited discovery to develop Monell facts	City opposed; court noted multiple amendment opportunities already	Denied — plaintiff had multiple chances to amend and failed to plead more than speculative/conclusory assertions

Key Cases Cited

Monell v. Dep’t of Social Servs., 436 U.S. 658 (1978) (municipal liability requires official policy, custom, or practice)
City of St. Louis v. Praprotnik, 485 U.S. 112 (1988) (limits on municipal liability and connection to policymaking)
City of Canton v. Harris, 489 U.S. 378 (1989) (failure-to-train standard requires deliberate indifference and causation)
Connick v. Thompson, 563 U.S. 51 (2011) (pattern of similar violations required to show municipal deliberate indifference)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions must be supported by factual allegations)
AE ex rel. Hernandez v. Cnty. of Tulare, 666 F.3d 631 (9th Cir. 2012) (Monell pleading requirements)
Hyun Ju Park v. City & Cnty. of Honolulu, 952 F.3d 1136 (9th Cir. 2020) (pattern requirement and notice to policymakers)
Trevino v. Gates, 99 F.3d 911 (9th Cir. 1996) (ratification and municipal liability principles)
Christie v. Iopa, 176 F.3d 1231 (9th Cir. 1999) (ratification requires approval of both decision and its basis)