The Ninth Circuit Court of Appeals affirmed the dismissal of a civil rights lawsuit filed by David Fink against the San Bernardino County Sheriff's Department and several of its officials, rejecting claims of unlawful seizure of funds following his arrest.
In a non-precedential memorandum opinion filed Wednesday, a three-judge panel consisting of Circuit Judges Bennett, Bade, and Sung unanimously upheld the U.S. District Court for the Central District of California's dismissal of Fink's action. The case was decided without oral argument, indicating the court found the legal issues sufficiently clear to resolve on the briefs alone.
Fink had sued the San Bernardino County Sheriff's Department and several individual defendants, including Chief Deputy Sheriff Sarkis Ohannessian, former Sheriff John McMahon, and Internal Affairs Lieutenant Edward Bachman. His lawsuit alleged the unlawful seizure of his funds following his arrest by sheriff's deputies.
The plaintiff brought multiple claims under federal civil rights law and state law. His federal claims were filed under 42 U.S.C. § 1983, the primary federal civil rights statute that allows individuals to sue state and local officials for violations of constitutional rights. Specifically, Fink alleged deprivation of property without due process of law, which would constitute a violation of his Fourteenth Amendment rights.
In addition to the constitutional claims, Fink brought several administrative and supervisory claims against the defendants. These included allegations of failure to train and supervise subordinates, suggesting that higher-ranking officials failed in their duty to properly oversee deputies who allegedly seized his funds. He also claimed defendants failed to investigate complaints, indicating potential problems with the department's internal accountability mechanisms.
Perhaps most notably, Fink's complaint included an allegation of fraud on the court, a serious accusation suggesting that defendants made material misrepresentations or omissions to the judicial system during the proceedings. Such claims require a high burden of proof and are viewed skeptically by courts.
The case originated in federal district court under the supervision of District Judge Christina A. Snyder. The district court dismissed Fink's action, though the specific grounds for dismissal are not detailed in the available portion of the appeals court opinion. Federal courts can dismiss civil rights cases for various reasons, including failure to state a claim upon which relief can be granted, lack of jurisdiction, or qualified immunity for individual defendants.
The Ninth Circuit's review applied standard appellate procedures for examining district court dismissals. The court noted it reviews dismissals for failure to state a claim de novo, meaning it examines the legal questions fresh without deference to the lower court's conclusions. The court also indicated it reviews denials of leave to amend for abuse of discretion, suggesting Fink may have sought permission to file an amended complaint that was denied.
The appeals court cited *Brown v. Stored Value Cards, Inc.*, a 2020 Ninth Circuit decision that established precedent for reviewing dismissals and amendment denials in civil litigation. This citation suggests the court applied established legal standards rather than breaking new ground in civil rights law.
The opinion was designated "not for publication," meaning it carries limited precedential value and cannot be cited as binding authority except under specific circumstances outlined in Ninth Circuit Rule 36-3. This designation is common for routine appeals that apply well-established law to specific factual circumstances without creating new legal principles.
The case number 24-1372 indicates the appeal was filed in 2024, while the underlying district court case number 5:21-cv-01124-CAS-RAO shows the original lawsuit was filed in 2021. This timeline suggests the litigation proceeded through federal court for approximately three years before reaching final resolution.
Civil rights lawsuits against law enforcement agencies under Section 1983 face significant legal hurdles. Plaintiffs must demonstrate that defendants acted under color of state law to violate clearly established constitutional rights. Individual officers may claim qualified immunity, which protects them from liability unless they violated clearly established law that a reasonable officer would have known.
For municipal liability claims against sheriff's departments, plaintiffs must typically show that constitutional violations resulted from official policies, customs, or deliberate indifference by supervisory officials. These requirements make successful civil rights litigation challenging, particularly in cases involving property seizures where the legal standards can be complex.
The affirmance by the Ninth Circuit concludes Fink's federal court challenge, though he may have limited options for further appeal. The Supreme Court accepts only a small percentage of petitions for certiorari, and non-precedential circuit court decisions rarely receive high court review unless they conflict with other circuit court decisions or raise issues of national importance.
This case represents another instance where federal courts have rejected civil rights claims against California law enforcement agencies, reflecting the ongoing challenges plaintiffs face in holding police departments accountable through civil litigation.