Rafael Sandoval v. County of Sonoma
912 F.3d 509
| 9th Cir. | 2018Background
- Cal. Veh. Code §14602.6 authorizes a 30-day impound when an officer determines a person was driving "without ever having been issued a driver's license." Local agencies (Sonoma County and City of Santa Rosa) interpreted that phrase to exclude foreign licenses and thus impounded cars of drivers with only non‑California licenses.
- In 2011 Sonoma deputy impounded Sandoval’s truck though Sandoval had a valid Mexican license and a friend with a California license volunteered to retrieve the vehicle; Sandoval regained the truck after 30 days upon paying storage fees.
- In 2011 Santa Rosa officers impounded Ruiz’s truck at a checkpoint despite an expired Mexican license and a friend with a valid California license; Ruiz also regained possession after 30 days upon paying fees.
- Sandoval and Ruiz sued under 42 U.S.C. §1983 (Fourth Amendment seizure) and the California Bane Act; district court granted summary judgment for plaintiffs on §1983 claims, denied class certification, and granted defendants summary judgment on Bane Act claims.
- Ninth Circuit affirmed: held the particular warrantless 30‑day impounds were unreasonable under the Fourth Amendment as applied; municipality liability (Monell) was proper because local policies—not state law—caused the impounds; denial of class certification and summary judgment for defendants on Bane Act also affirmed on reasoning explained below.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 30‑day impounds under §14602.6 here violated the Fourth Amendment | Sandoval/Ruiz: impounds were warrantless seizures and unreasonable once a licensed driver could take possession | County/City: impounds justified by community‑caretaking and state interest in deterring unlicensed driving; statute authorizes the 30‑day hold | The impounds were unreasonable on these facts; community‑caretaking did not justify continued retention after a licensed person could take the vehicle (affirmed plaintiff §1983 wins) |
| Whether municipality could be held liable under Monell for the impounds | Plaintiffs: County/City policies interpreting §14602.6 caused the constitutional violations | County/City: they merely enforced state law, so no municipal policymaker liability | Held for plaintiffs: state law (§310) defines "driver's license" to include foreign licenses, so local policies (not state law) caused the unconstitutional impounds; Monell liability affirmed |
| Whether the proposed classes should be certified (commonality/typicality) | Plaintiffs: all members injured by the same 30‑day impound theory | Defendants: legality depends on case‑specific facts (e.g., whether a licensed person could retrieve vehicle) so no common answer | District court did not abuse discretion: lack of commonality/typicality because 30‑day impounds are not per se unconstitutional; factual variations defeat classwide resolution (certification denied) |
| Whether Bane Act liability attaches automatically from Fourth Amendment violation | Plaintiffs: Fourth Amendment violation suffices for Bane Act recovery | Defendants: plaintiffs must show independent coercion or specific intent to violate rights | Affirmed for defendants: plaintiffs could not show defendants had specific intent to violate clearly established Fourth Amendment rights in 2011 (legal clarity arrived later in Brewster) |
Key Cases Cited
- Brewster v. Beck, 859 F.3d 1194 (9th Cir. 2017) (30‑day impounds are Fourth Amendment seizures and community‑caretaking exception is fact specific)
- Miranda v. City of Cornelius, 429 F.3d 858 (9th Cir. 2005) (community‑caretaking exception does not justify continued warrantless tow as a deterrent)
- United States v. Cervantes, 703 F.3d 1135 (9th Cir. 2012) (vehicles may be removed when they jeopardize public safety and traffic flow)
- United States v. Sullivan, 797 F.3d 623 (9th Cir. 2015) (totality of circumstances can sometimes justify prolonged warrantless seizure)
- Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978) (municipal liability requires an unconstitutional policy or custom)
- Wal‑Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011) (commonality requirement for class certification)
- Lyall v. City of Los Angeles, 807 F.3d 1178 (9th Cir. 2015) (Bane Act requires coercion separate from the constitutional violation in some contexts)
- Reese v. County of Sacramento, 888 F.3d 1030 (9th Cir. 2018) (Bane Act may be satisfied by coercion inherent in a Fourth Amendment violation if there was specific intent to violate rights)
- Soldal v. Cook County, 506 U.S. 56 (1992) (seizure requires meaningful interference with possessory interests)