Lull v. County of Sacramento
2:20-cv-00165
E.D. Cal.May 20, 2020Background
- Plaintiff Christopher Lull filed this action challenging denial and revocation of business licenses by Sacramento County; defendants moved to dismiss.
- A related case (Autotek Inc. & Christopher Lull v. County of Sacramento, No. 2:16-cv-01093 KJM CKD) is pending, with defendants’ motion for summary judgment raising whether Lull’s property violated county building/zoning codes.
- The County’s asserted basis for denying/revoking the business licenses in the present case was that Lull’s property violated those same codes.
- The court found the legal and factual questions in the related case likely to settle or simplify issues in this action and to avoid inconsistent judgments and duplicative work.
- Applying the Landis/Cmax factors, the court concluded prejudice to Lull would be minimal and a stay would not be indefinite; it therefore stayed this case pending resolution of the related case’s summary judgment motion.
- The parties must notify this court of the summary judgment outcome within seven days of the decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether this action should be stayed pending resolution of a related case | Lull contends the case is simply a question of business licensing law and should proceed | Defendants argue the related case will decide whether the property violated codes—the core basis for license denial/revocation—so resolution could dispose or narrow claims here | Court stayed the case pending decision on the related case’s summary judgment motion |
| Whether the related proceeding is sufficiently "related" to justify a Landis stay | Lull disputes need to wait; frames issue as licensing law only | Defendants stress overlapping factual/legal issue: whether property violated building/zoning codes, which underlies the licensing decisions | Court found the related proceeding likely to settle dispositive or narrowing issues and therefore related for stay purposes |
| Whether a stay would cause unfair prejudice or undue delay to plaintiff | Lull argues waiting longer is prejudicial | Defendants note not staying risks post-judgment motions and duplicative proceedings, potentially extending resolution anyway | Court found prejudice minimal and stay unlikely to lengthen overall resolution time |
| Whether the stay’s length is reasonable | Lull implied concern about indefinite delay | Defendants point to the pending summary judgment briefing and near-term adjudication | Court concluded the summary judgment motion’s timing made an unreasonably long stay unlikely and limited the stay to the summary judgment decision |
Key Cases Cited
- Landis v. North American Co., 299 U.S. 248 (U.S. 1936) (district courts have inherent power to stay suits)
- Leyva v. Certified Grocers of California, Ltd., 593 F.2d 857 (9th Cir. 1979) (independent proceedings bearing on a case can justify a stay)
- Dependable Highway Exp., Inc. v. Navigators Ins. Co., 498 F.3d 1059 (9th Cir. 2007) (limits on Landis stays and relatedness standard)
- CMAX, Inc. v. Hall, 300 F.2d 265 (9th Cir. 1962) (factors for evaluating whether to grant a stay)
- Lockyer v. Mirant Corp., 398 F.3d 1098 (9th Cir. 2005) (stay pending another proceeding must likely conclude within a reasonable time)