Smith v. Martin
1:18-cv-00307
| E.D. Cal. | Apr 2, 2024Background
- Augustus Joshua Crawford was shot and killed by Bakersfield Police officers after fleeing a traffic stop in November 2017; he was unarmed at the time of the fatal shots.
- Crawford’s mother and two minor children filed claims under federal and state law, including wrongful death, excessive force, and municipal liability, naming the City of Bakersfield, certain officers, and Doe defendants.
- Plaintiffs brought parallel suits which were consolidated; some defendants and claims were previously dismissed.
- In 2022, defendants moved for partial summary judgment on several issues, including standing, municipal liability, punitive damages, and the Doe defendants.
- The court considered the motion under Rule 56, granting summary judgment for the defendants on all four key issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held (Court's Ruling) |
|---|---|---|---|
| Standing for Wrongful Death | Smith (mother) qualified as dependent under Cal. law due to $100/month support/groceries | Support was occasional/gift-based and not for “necessaries of life”; no evidence of dependency | Smith lacked standing; summary judgment granted on wrongful death claim |
| Standing for Survival Action | Smith is a “successor in interest” to assert survival claims on behalf of decedent | Only personal representative or estate beneficiaries (his children) may bring survival claims | Smith not a beneficiary; no standing for survival claim |
| Municipal Liability (Monell) | City ratified unconstitutional acts, failed to train/discipline, and had deficient policies | No final policymaker ratification, no pattern of violations, policy met constitutional standards | No evidence supporting Monell liability; summary judgment for City |
| Punitive Damages & Doe Defendants | Sought punitive damages, and to later name Doe defendants after deadline | Punitive damages against City barred by statute; Doe defendants not timely named | No punitive damages against City; Doe defendants dismissed; no leave to amend for delay |
Key Cases Cited
- Monell v. Dep't of Social Services, 436 U.S. 658 (municipal liability under § 1983 requires official policy/custom)
- Celotex Corp. v. Catrett, 477 U.S. 317 (burden of proof and summary judgment standards)
- Scott v. Harris, 550 U.S. 372 (facts viewed in light most favorable to nonmovant on summary judgment)
- Connick v. Thompson, 563 U.S. 51 (failure to train claims under § 1983 require pattern or obviousness)
- City of Canton v. Harris, 489 U.S. 378 (municipal liability for failure to train under “deliberate indifference”)
- Fairley v. Luman, 281 F.3d 913 (policy must be deliberate choice by final policymaker for Monell liability)
- Lytle v. Carl, 382 F.3d 978 (ratification requires actual approval by final policymaker)