Stefan Wilcox v. City of Los Angeles, 20-56343

Stefan Wilcox, pro se, sued the City of Los Angeles, the LAPD, officer Erik Miranda, Los Angeles County, the Los Angeles County Sheriff’s Department, the Los Angeles County Probation Department, and probation officers Scott Arnow and Jose Perez asserting false arrest (Fourth Amendment), §1983 civil-rights deprivation, §1985/§1986 conspiracy, and California vicarious-liability claims.
The district court granted motions to dismiss against the City, LAPD, Miranda, County, Probation Department, and probation officers, and entered summary judgment for the County and the Sheriff’s Department.
The court held Wilcox’s false-arrest/ Fourth Amendment claims against City/LAPD/Miranda were precluded by a preliminary hearing probable-cause finding and thus could not be relitigated in the civil action.
The court held there was no evidence of a County or Sheriff’s Department policy, custom, or practice causing constitutional deprivation (Monell), and no evidence of a conspiracy supporting §1985/§1986 claims; it therefore granted summary judgment on those federal claims.
Wilcox’s state-law vicarious-liability claims were dismissed for failure to comply with the California Tort Claims Act and as duplicative; the district court denied further leave to amend as futile after multiple amendment opportunities.
The Ninth Circuit reviewed de novo and affirmed the district court’s dismissals and summary judgment in all respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Relitigation of preliminary-hearing probable cause (false arrest)	Wilcox contends arrest/false arrest claims under the Fourth Amendment	Defendants argue preliminary-hearing probable-cause finding precludes relitigation	Dismissed — issue preclusion applies; claims barred
Monell §1983 liability against County/Sheriff	Wilcox alleges deprivation of civil rights caused by county policy/custom	County and Sheriff argue no policy, custom, or practice evidence exists	Summary judgment for County/Sheriff — no Monell liability
§1985/§1986 conspiracy claims	Wilcox alleges conspiratorial deprivation of rights	Defendants assert no evidence of any conspiracy	Summary judgment for County/Sheriff — conspiracy claims fail
State-law vicarious liability & CTCA compliance	Wilcox asserts state vicarious-liability claims against county actors	Defendants contend Wilcox failed to present timely, fair-tied tort claims and claims are duplicative	Dismissed — CTCA noncompliance and duplicative; no leave to amend granted

Wige v. City of Los Angeles, 713 F.3d 1183 (9th Cir. 2013) (preclusive effect of preliminary-hearing probable-cause findings on false-arrest suits)
Connick v. Thompson, 563 U.S. 51 (U.S. 2011) (Monell municipal-liability standard requires policy or custom causation)
Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (U.S. 1978) (municipal liability requires action pursuant to official policy)
United Bhd. of Carpenters & Joiners of Am., Loc. 610, AFL-CIO v. Scott, 463 U.S. 825 (U.S. 1983) (elements required to state a §1985(3) claim include a conspiracy)
Karim-Panahi v. Los Angeles Police Dep’t, 839 F.2d 621 (9th Cir. 1988) (§1986 claim depends on a valid §1985 claim)
Stockett v. Ass’n of Cal. Water Agencies Joint Powers Ins. Auth., 34 Cal.4th 441 (Cal. 2004) (complaint causes must be fairly reflected in timely Government Claims Act claims)
Nguyen v. Endologix, Inc., 962 F.3d 405 (9th Cir. 2020) (denial of leave to amend is appropriate after repeated futile amendment opportunities)
Adams v. California Dep’t of Health Servs., 487 F.3d 684 (9th Cir. 2007) (district court discretion to dismiss duplicative later-filed actions)
Prodanova v. H.C. Wainwright & Co., LLC, 993 F.3d 1097 (9th Cir. 2021) (standard of review for Rule 12(b)(6) dismissal)
Living Designs, Inc. v. E.I. Dupont de Nemours & Co., 431 F.3d 353 (9th Cir. 2005) (standard of review for summary judgment)