Young v. County of Los Angeles, et al.

This case arose from a traffic stop for a seatbelt violation in which a Los Angeles County Sheriff pepper sprayed plaintiff and struck him with a baton after plaintiff exited his vehicle and disobeyed the Sheriff's order to reenter it. Plaintiff filed this action against the Sheriff and the county, claiming that the Sheriff's use of force was excessive under the Fourth Amendment and that the Sheriff's conduct constituted false imprisonment and negligence under California tort law. The court affirmed the district court's grant of summary judgment to the Sheriff with respect to plaintiff's false imprisonment claim because the Sheriff had lawful authority to arrest plaintiff on account of his violation of Cal. Penal Code 148(a)(1). The court held, however, that the use of intermediate force was unreasonable and the suspect clearly posed no threat to the officer or the public safety. Therefore, the court reversed as to the dismissal of plaintiff's excessive force and negligence claims.