Maidhof et al v. Celaya et al

Filing 88

SUMMARY OF HOLDINGS --- The attached document summarizes the court's holdings on the parties' pending Rule 56 motions. The court hopes that this will inform the parties' upcoming settlement conference. A full order disposing of the motions will follow by Monday, February 29, 2016. Signed by Judge Laurel Beeler on 2/26/2016. (lblc3S, COURT STAFF) (Filed on 2/26/2016)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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San Francisco Division

United States District Court
Northern District of California

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MEGAN SHEEHAN,

Case No.14-cv-03156-LB

Plaintiff,
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v.

SUMMARY OF HOLDINGS ON
PENDING RULE 56 MOTIONS

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BAY AREA RAPID TRANSIT, et al.,

[ECF Nos. 73, 75, 77]

Defendants.
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SUMMARY OF HOLDINGS

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Each party has moved for summary judgment. (ECF Nos. 73, 75, 77.) The court indicated its

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intended ruling on these motions at the recent summary-judgment hearing — save for the question

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of what might be called “de facto policy” liability under Monell v. New York City Dept. of Social

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Svcs., 436 U.S. 658 (1978). The court has now reached final decisions on all the issues presented.

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To inform the parties’ upcoming settlement conference, this order summarizes the court’s

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holdings. A full order will follow by Monday, February 29, 2016.

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The court denies Ms. Sheehan’s motion. The court grants Officer Stolzman and the City of

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Oakland’s motion. The court partly grants and partly denies Officer Pianta and BART’s motion.

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The court specifically holds as follows:

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

A jury question exists on whether Officer Pianta used excessive force. The record does not
permit a decision as a matter of law for either Ms. Sheehan or BART and Officer Pianta.

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ORDER (No.14-cv-03156-LB)

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

A genuine dispute of material fact prevents the court from deciding whether Officer Pianta
is entitled to qualified immunity; the parties’ summary-judgment motions are therefore
denied on this issue.



Officer Stolzman, as a matter of law, was not an “integral participant” in the “takedown”
that injured Ms. Sheehan.



BART and the OPD cannot be held liable on a Monell ratification theory merely because
their post-incident investigations exonerated Officers Pianta and Stolzman.



There is no evidence that the OPD maintained an unconstitutional policy or custom for
Monell purposes.

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The plaintiff has not adduced sufficient evidence to raise a triable claim that BART
maintained an unconstitutional policy or custom for Monell purposes.



The plaintiff’s claims under the Fourteenth Amendment and California’s Bane Act (Cal.
Civ. Code § 52.1) track the disposition of her Fourth Amendment excessive-force claim.

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United States District Court
Northern District of California

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The court will therefore dismiss with prejudice all claims against Officer Stolzman and BART.

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The court will dismiss with prejudice Ms. Sheehan’s Monell claims . Her claims against Officer

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Pianta will go forward.

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Dated: February 26, 2016
______________________________________
LAUREL BEELER
United States Magistrate Judge

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14-cv-03156-LB