Sinsukthaworn v. City of Calistoga
3:22-cv-04644-JSC
N.D. Cal.May 19, 2025Background
- Plaintiffs, licensed cannabis cultivators, had their marijuana plants seized and destroyed by the County of Napa and two officers after a box truck carrying cannabis from their facility was stopped for lacking a distribution license.
- The seizure followed a state court search warrant after one officer attested that Plaintiffs violated the conditions of their cultivation license by unlawful transport and sale.
- Plaintiffs were later charged criminally, pled no contest to public nuisance, and subsequently filed this civil rights suit under § 1983 and related state law claims.
- Plaintiffs allege judicial deception in the warrant, constitutional violations, inadequate officer training, and seek Bane Act damages and sanctions for spoliation after investigatory photographs were destroyed.
- The case came before the court on Defendants’ motion for summary judgment and Plaintiffs’ motion for sanctions; oral argument was held in early 2025.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial deception by officer in warrant | Officer omitted facts/laws showing lawful activity | Omissions of law not actionable; no intent proven | No evidence Walsh knew plants were waste; No deception |
| Liability of non-affiant officer | Scannell omitted exculpatory info, so integral | No underlying constitutional violation | No judicial deception/integral participation; No liability |
| Monell/failure to train (municipal) | Officers poorly trained on cannabis regulations | 2 officers w/o training is insufficient as "pattern" | No pattern or obvious deficiency; Summary judgment for County |
| Sanctions for spoliation (photos deleted) | Destruction of photos prejudiced case | No intent to deprive; routine deletion policy | Failure to preserve unreasonable but no prejudice; No sanctions |
Key Cases Cited
- Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden-shifting standard)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment evidentiary burden and inferences)
- Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (municipal § 1983 liability standards)
- Connick v. Thompson, 563 U.S. 51 (standard for municipal liability based on failure to train)
- Illinois v. Gates, 462 U.S. 213 (probable cause standard for search warrants)
- Leon v. IDX Sys. Corp., 464 F.3d 951 (spoliation and prejudice standard)
- Liston v. Cnty. of Riverside, 120 F.3d 965 (judicial deception by omission of material facts)
- Bravo v. City of Santa Maria, 665 F.3d 1076 (requirements for judicial deception claims under § 1983)