F.V. v. City of Anaheim
The dispositive issue in this case is whether, under principles of collateral estoppel, a judgment in a federal lawsuit on federal civil rights claims based on police conduct bars state law claims brought in state court based on the same conduct. We conclude collateral estoppel bars the state court lawsuit.
Adolf Anthony Sanchez Gonzalez (Decedent) was shot and killed in an incident with two Anaheim police officers. His mother and minor daughter (by and through her guardian ad litem, David Vazquez) filed a complaint in federal court (the Federal Complaint) against the City of Anaheim and the two officers. The Federal Complaint asserted civil rights claims under 42 United States Code section 1983 and five state law claims. The federal district court granted summary judgment in favor of the defendants on the civil rights claims and concluded the police officers did not use excessive force, act unreasonably, engage in conduct that shocked the conscience, or engage in conduct amounting to an independent violation of the Fourth Amendment to the United States Constitution. The federal court declined to exercise supplemental jurisdiction over the state law claims and dismissed them without prejudice.
Comments on F.V. v. City of Anaheim