Sandoval v. County of Sonoma, 3:11-cv-05817

Plaintiffs allege § 1983 and Cal. Civ. Code § 52.1 claims arising from impoundments under Cal. Veh. Code § 14602.6.
Avendano Ruiz had a valid Mexican driver’s license; SRPD purportedly treated foreign licenses as never issued under § 14602.6.
Mateos-Sandoval’s truck was impounded after a traffic stop in January 2011; he later sought hearings but was told he was ineligible.
Mateos-Sandoval and Avendano Ruiz paid storage/administrative fees and regained possession after 30 days.
The district court previously granted partial dismissal; this order addresses personal-capacity claims, a third claim, and § 52.1 claims, with some stays and dismissals.
Court holds oral argument unnecessary; motions granted in part and denied in part.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Freitas’s personal-capacity §1983 claim survives	Freitas’s policy of interpreting §14602.6 caused the seizure.	Freitas is immune under statutory immunities.	Survives; not shielded by immunity.
Whether Schwedhelm’s personal-capacity §1983 claim survives	Schwedhelm approved a policy interpreting §14602.6 to permit 30-day impounds for foreign-licensees.	Schwedhelm’s actions were within immunity defenses.	Survives; allegations are sufficient to state a claim.
Whether City Defendants’ third claim (due process notice) survives	Plaintiffs lacked adequate notice of storage hearings under §14602.6(b).	Notice provided was adequate and reasonably calculated.	Dismissed with prejudice.
Whether §52.1 claims against County defendants are viable, including immunities and stay	County actions violated rights; should proceed; no immunity bars liability.	Immunities apply; claims should be stayed pending sovereign-immunity appeal.	§52.1 claims against County defendants denied for some counts; immunity issues unresolved; official-capacity claims stayed pending appeal; personal-capacity claims proceed.
Whether the County’s immunity defenses bar §52.1 claims	Immunity does not bar Bane Act claims given intentional coercion.	Immunities apply to §52.1 claims.	Immunities not applicable to the asserted §52.1 claims; stay granted on official-capacity claims pending appeal.

Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) (Due process notice must be reasonably calculated to inform affected parties)
Gete v. I.N.S., 121 F.3d 1285 (9th Cir. 1997) (Due process requires notice of factual basis for seizure and statutory provisions)
Venegas v. County of Los Angeles, 32 Cal.4th 820 (2004) (Bane Act requires coercion in deprivation of rights; not ordinary torts)
Shoyoye v. County of Los Angeles, 203 Cal.App.4th 947 (2012) (Coercion must be beyond negligent error; unresolved scope of 52.1)
Cameron v. State of California, 7 Cal.3d 318 (1972) (Section 820.4 immunity requires showing due care in enforcement)
Johnson v. State of California, 69 Cal.2d 782 (1968) (Immunity requires a policy decision balancing risks and advantages)
Mullane v. Central Hanover Bank & Trust Co. (duplicate entry for emphasis), 339 U.S. 306 (1950) (Due process notice standard reiterated)