Lyall v. City of Los Angeles, No. 13-56122 (9th Cir. 2015)
Annotate this CasePlaintiffs filed suit under 42 U.S.C. 1983, alleging that police officers' warrantless entry into a warehouse during a musical event and fundraiser, and their subsequent search and detention of everyone inside, violated the attendees' First and Fourth Amendment rights. The district court granted summary judgment to defendants with respect to the warrantless-search claims and with respect to the unreasonable-seizure claim of Plaintiff Javier Cortez. The court agreed that the majority of the plaintiffs lack standing to challenge the warrantless entry, concluded that the district court’s holding that Cortez is subject to the Heck bar was correct, and rejected all of plaintiffs’ claims of error regarding the jury instructions given at trial. However, the court concluded that Plaintiffs Cortez and Elizabeth Lopez, who were organizers of the event and thus were in possession of the warehouse on the night at issue, have standing to challenge the officers' entry into the warehouse. Accordingly, the court reversed the district court's grant of summary judgment as to that issue. The court remanded the warrantless-entry claims for trial.
Court Description: Civil Rights. The panel affirmed the district’s judgment entered following a jury verdict, affirmed the district court’s summary judgment in favor of defendants on the basis of Heck v. Humphrey, 512 U.S. 477 (1994), and reversed the district court’s summary judgment in favor of defendants with respect to a warrantless-entry claim, in an action brought pursuant to 42 U.S.C. § 1983. LYALL V. CITY OF LOS ANGELES 3 Plaintiffs alleged that police officers violated their First and Fourteenth Amendment rights when they entered, without a warrant, a warehouse where plaintiffs were attending a musical event and subsequently searched and detained them. Affirming the district court, the panel held that the majority of the plaintiffs, who were merely attending the event, lacked standing to challenge the warrantless entry because they had no grounds upon which to claim a reasonable expectation of privacy in the warehouse. The panel further held that event organizer Javiar Cortez was subject to the Heck bar regarding his unreasonable seizure claim because he had not challenged the validity of his California Penal Code § 415 disturbing the peace conviction, arising from the encounter with the officers. The panel rejected all of the plaintiffs’ claims of error regarding the jury instructions given at trial. The panel reversed the district court’s grant of summary judgment with respect to Cortez’s and plaintiff Elizabeth Lopez’s warrantless-entry claims. The panel held that Cortez and Lopez, who were organizers of the event and thus were in possession of the warehouse on the night of the event, had standing to challenge the officers’ entry into the warehouse. The panel accordingly remanded their warrantless-entry claims for trial.
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