Museum of Handcar Technology LLC v. Transportation Agency for Monterey County
5:24-cv-08598
N.D. Cal.Apr 14, 2025Background
- The Museum of Handcar Technology LLC operated guided handcar tours on a historic railway under lease agreements with the Transportation Agency for Monterey County (TAMC) and the City of Marina.
- In 2023–2024, the Museum publicly opposed TAMC's plans to remove parts of the railway for the SURF! Busway Project, raising constitutional, regulatory, and funding concerns.
- Following the Museum’s opposition, TAMC (citing the Museum’s actions as disruptive) declined to renew the lease, and, along with the City, initiated state unlawful detainer actions to evict the Museum.
- The Museum sued TAMC and the City in federal court under 42 U.S.C. § 1983 for First Amendment retaliation and sought a preliminary injunction to halt the eviction process and interference with its possession.
- The City dismissed its unlawful detainer action, mooting the injunctive relief request as to the City; the dispute continued against TAMC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| First Amendment Retaliation | Lease non-renewal was retaliation for opposing project | Decision driven by project needs, not retaliation | Museum showed likelihood of success on retaliation claim |
| Likelihood of Irreparable Harm | Eviction would chill free speech and destroy business | Museum can be compensated; project delays costly | Irreparable harm likely due to loss of First Amendment rights |
| Balance of Hardships/Public Interest | Public interest favors protection of free speech | Project delay harms public transit interest | Balance tips in Museum’s favor at this stage |
| Scope of Injunction/Relief | Sought broad halt to all detainer actions and possession | Preliminary stop hinders state process; alternate remedies possible | Granted tailored injunction: TAMC can’t evict pending outcome |
Key Cases Cited
- Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (setting standard for granting preliminary injunctions)
- Perry v. Sindermann, 408 U.S. 593 (1972) (government may not deny benefit for speech)
- Hartman v. Moore, 547 U.S. 250 (2006) (retaliatory motives violate First Amendment)
- Coszalter v. City of Salem, 320 F.3d 968 (9th Cir. 2003) (loss of government benefit can be chilling)
- Pembaur v. City of Cincinnati, 475 U.S. 469 (1986) (municipal liability for official policy)