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HomeMy WebLinkAbout2012-06-29_Scott_Andrews_Claudia_Rohr_v_County_of_Hawaii_Order_Granting_Defendants'_Motion_to_Dismiss Case 1:1 0-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 1 of 31 PagelD #: 587 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAII SCOTT L. ANDREWS, CLAUDIA ) CV. NO. 10-00749 DAE-KSC J. ROHR, ) Plaintiffs, ) vs. ) COUNTY OF HAWAII; ) LAWRENCE K. MAHUNA; ) SAMUEL THOMAS; GEORGE ) MAKUA; ROMEO FUVIAVA; ) BRIAN MILLER; BENNY ) RUFFOLO; ANNETTE COLLINS; ) MIRIAM KANAEHOLO; DOE ) DEFENDANTS 1-25, ) Defendants. ) ORDER GRANTING DEFENDANTS' MOTION TO DISMISS On June 15, 2012, the Court heard Defendants' Motion to Dismiss Plaintiffs' Second Amended Complaint ("Motion"). (Doc. # 64.) Scott L. Andrews and Claudia J. Rohr, proceeding rp o se, appeared at the hearing on behalf of themselves; Deputy Corporation Counsel Michael J. Udovic appeared on behalf of Defendants. After reviewing Defendants County of Hawaii, Lawrence K. Mahuna, Samuel Thomas, George Makua, Romeo Fuviava, Brian Miller, Benny Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 2 of 31 PagelD #: 588 Ruffolo, Annette Collins, Miriam Kanaeholo, and Richard Itliong's (collectively, "Defendants") Motion and the supporting and opposing memoranda, the Court GRANTS Defendants' Motion to Dismiss. BACKGROUND Plaintiffs Scott Andrews ("Andrews") and his wife Claudia Rohr ("Rohr"), proceeding pro se, filed this action against Defendants Hawaii County and various members of the Hawaii County Police Department. The factual allegations in Plaintiffs' Complaint date back to April 21, 2008. ("SAC," Doc. # 58, ¶ 27.) Plaintiffs claim that on that day, Andrews was confronted and attacked by a man named Alexander Lewis ("Lewis"). (Id. ¶¶ 29-30.) Plaintiffs allege that Andrews "pressed charges" against Lewis, but that Lewis was not arrested or prosecuted. (Id. ¶ 32.) Plaintiffs further allege that a few days after the April 21, 2008 incident, assault rifles were painted on local roadways pointing toward Plaintiffs' driveway. (Id. ¶ 33.) Plaintiffs, suspecting Lewis or Lewis' "social network" was responsible, reported it to Defendant police official Samuel Thomas ("Thomas") and deputy prosecutor Mitchell Roth ("Roth"). (Id. ¶ 33.) Plaintiffs further allege that Lewis began harassing Plaintiffs with threats and "launched a slanderous and racially motivated campaign to turn locals and the Hawaiian community against Plaintiffs." (Id. ¶ 35.) Plaintiffs allege that Lewis' "pattern of 2 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 3 of 31 PagelD #: 589 harassment continued on a regular basis, unabated by Hawaii County's police or prosecutors." (Id. ¶ 39.) On December 12, 2008, Lewis allegedly drove his truck toward Andrews twice. (Id. ¶ 42.) Andrews called 911 from a cell phone and was connected to dispatcher, Defendant Annette Collins ("Collins"), who allegedly responded with "discriminatory animus" and accused Andrews of"harassing people in the park." (Id. ¶¶ 43-44.) Plaintiffs allege that Lewis approached Andrews, who took out and pointed a hand-held video camera at Lewis." (Id. ¶ 46.) Lewis allegedly knocked Andrews' cell phone out of his hand, disconnecting the 911 call, and assaulted Andrews again, causing injuries that required Andrews to go to the hospital. (Id. ¶¶ 47, 50-52, 57.) Plaintiffs allege that Collins "retaliated" against Andrews for his use of a video camera and "omitted to enter into the dispatch system this information that tended to inculpate Lewis." (Id. ¶ 49.) Plaintiffs allege that after the assault, they tried numerous times to contact the police and request assistance. (Id. ¶¶ 53-57, 58-59.) According to Plaintiffs, however, the Defendants refused to send an officer to their home or conduct an investigation. (Id. ¶ 60.) Plaintiffs allege that Rohr drove to the Hilo police station and confronted Defendant police sergeant George Makua ("Makua") 3 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 4 of 31 PagelD #: 590 about the assault, but that Makua "acted with discriminatory animus" against Rohr "in retaliation for exercising her First Amendment right to broadcast the truth" about the assault. (Id. ¶ 60.) According to Plaintiffs, Rohr confronted other police officials, including Defendant Central Dispatch Division shift supervisor Miriam Kanaeholo, who withheld information about Andrews' calls and "expressed her discriminatory bias against [Andrews'] use of a video camera." (Id. ¶ 61.) Andrews checked into the Hilo Medical Center Emergency Room around 5:45 p.m. that day and Defendant Benny J. Ruffolo ("Ruffolo") allegedly agreed to meet Andrews at the hospital for an interview. (Id. ¶¶ 55-56.) However, Plaintiffs claim that Ruffolo never contacted them. (Id. ¶ 58a.) Instead, Ruffolo allegedly, under the supervision of Makua, composed an incident report, an application for an arrest warrant, and an "All Points Bulletin" to arrest Andrews for a felony assault charge. (Id. ¶ 66.) Plaintiffs also allege that Defendants police officer Romeo Fuiava ("Fuiava"), Richard Itliong ("Itliong"), and several other unnamed defendants allegedly went to the hospital and tried to get Andrews civilly committed but were unsuccessful. (Id. ¶¶ 67-69.) Plaintiffs allege that Fuiava, Itliong and the others then proceeded to arrest Andrews while he was in the Emergency Room. (Id. ¶¶ 69, 71.) 4 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 5 of 31 PagelD #: 591 Plaintiffs claim that Andrews was subsequently taken to a holding jail at the Hilo Police Station after Andrews refused to sign the hospital release form. (Id. ¶¶ 72, 73-74.) Plaintiffs allege that Defendants did not inform Andrews or Rohr of the subject matter of the arrest. (Id. ¶¶ 73-74.) According to Plaintiffs, Andrews repeatedly told the officers that he thought he was going to have a heart attack but they initially refused to take him back to the hospital. (Id. ¶ 74.) Plaintiff Rohr repeatedly requested to see Andrews but was denied access to him. (Id. ¶ 75.) Rohr drove to Thomas' home and left a message with his son, asking for help, but Thomas never contacted Rohr. (Id. ¶ 76.) Plaintiffs claim that Andrews was eventually taken to the hospital at about 10:30 p.m. and was diagnosed with an abnormal electrocardiogram. (Id. ¶ 77.) Plaintiffs allege that the attending physician released Andrews from the hospital into home care and did not authorize his release to return to jail conditions. (Id. ¶ 78.) Plaintiffs allege that Andrews did not receive any of the care recommended by the hospital doctors and that his health worsened under the "harsh conditions in jail" so that Andrews was returned to the hospital the next morning, December 13, 2008, at 10 a.m. (Id. ¶ 79.) Plaintiffs allege that Defendant police detective Brian Miller ("Miller") interviewed Andrews the 5 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 6 of 31 PagelD #: 592 morning of December 13, 2008 before Plaintiff was allowed a phone call or a visit from Rohr. (Id. ¶ 80.) Miller allegedly detained Andrews for another 24 hours for "a cover-up scheme and/or punishment" before setting Andrews' bail. (Id. ¶ 82.) Plaintiffs allege that they were never verbally informed of the charge(s) against Andrews and was ultimately provided a "poor copy of the bail receipt that made the charges undecipherable." (Id. ¶ 83-84.) According to Plaintiffs, the prosecutor declined to prosecute and dismissed the case. (Id. ¶ 84.) Plaintiffs initiated the instant action on December 15, 2010. (Doc. # 1.) On September 20, 2011, this Court dismissed Plaintiffs' Initial Complaint without prejudice. (Doc. # 39.) The Court determined that the statute of limitations for Plaintiffs' claims expired before the Initial Complaint was filed. However, the Court observed that "it may be possible for Plaintiffs to plead sufficiently that Defendants could be estopped from raising a statute of limitations defense if provided the opportunity to amend their Complaint." (Id. at 16.) The Court therefore granted Plaintiffs leave to amend and on November 3, 2011, Plaintiffs filed a First Amended Complaint ("FAC"). ("FAC," Doc. # 41.) Defendants subsequently filed a Motion to Dismiss the FAC. (Doc. # 44.) On February 9, 2012, the Court dismissed the FAC with leave to amend. (Doc. # 56.) The Court found that Plaintiffs did not allege sufficient facts 6 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 7 of 31 PagelD #: 593 to show that they are entitled to equitable tolling or that equitable estoppel applies to toll the statute of limitations for Plaintiffs' § 1983 claims. (Id. at 11-16.) The Court also determined that the FAC failed to satisfy the basic pleading standards under Federal Rule of Civil Procedure 8 (id. at 16-18), and that Rohr lacks standing to assert a § 1983 claim based on the alleged false arrest of Andrews (id. at 19). The Court gave Plaintiffs leave to amend. (Id. at 21.) On March 27, 2012, Plaintiffs filed the present Second Amended Complaint ("SAC"). ("SAC," Doc. # 58.) The SAC states the following causes of action: (1) First Cause of Action: "Fourteenth Amendment Right—Special Duty to Provide Medical Care to Detainees and Negligence Under State Law Claim" (Id. ¶¶ 90-93.) Plaintiffs allege that Defendants Makua, Thomas, and Mahuna are liable for Andrews' medical injuries resulting from his arrest and detention. Plaintiffs allege that Thomas and Mahuna are liable for failure to supervise and failure to promulgate effective policies in this regard, and that Hawaii County was negligent in its "Special Duty to provide medical care" and is liable under § 1983 because inadequate policies and procedures and a lack of training and supervision resulted in Andrews' injuries. 7 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 8 of 31 PagelD #: 594 (2) Second Cause of Action: "Retaliation Against Plaintiffs Andrews and Rohr For Exercising First Amendment Rights." (Id. ¶ 94.) Plaintiffs allege that Defendants Ruffolo, Makua, Fuiava, Itliong, Miller and Does 1-25 acted with discriminatory animus against Andrews "in retaliation for exercising his First Amendment right to use a video camera" and acted with discriminatory animus against Rohr "in retaliation for exercising her First Amendment right to complain about officers." Plaintiffs also allege that Defendants Thomas and Mahuna retaliated against Plaintiffs for "bringing the FBI in to investigate a racially based assault." (3) Third Cause of Action: "False Arrest and False Detention" of Andrews in violation of the Fourth, Fifth, Ninth and Fourteenth Amendments. (Id. ¶¶ 95-100.) Plaintiffs assert that Defendants "unconstitutionally concealed exculpatory information from the probable cause analysis." Plaintiffs further allege that Andrews has suffered physical and emotional injuries and that Rohr has suffered a loss of consortium as well as physical and emotional injuries. The SAC also claims that Defendants are equitably estopped from asserting a statute of limitations defense. (SAC ¶¶ 85-89.) On April 10, 2012, Defendants filed the instant Motion to Dismiss. (Doc. # 64.) Plaintiffs did not file a timely Opposition, but on May 24, 2012 filed 8 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 9 of 31 PagelD #: 595 a Motion for Leave to File Plaintiffs' Memorandum in Opposition and an attached Memorandum in Opposition. (Doc. # 71). On May 25, 2012, the Court granted Plaintiffs' Motion for Leave to File an Opposition. (Doc. # 72.) On the same day, Plaintiffs filed a Memorandum in Opposition. (Doc. # 73.) On May 30, 2012, Defendant Richard Itliong filed a Joinder to Defendants' Motion to Dismiss. (Doc. # 74.) On June 4, 2012, Defendants filed a Reply to Plaintiffs' Opposition. (Doc. # 76.) STANDARD OF REVIEW Pursuant to Federal Rule of Civil Procedure 12(b)(6), a motion to dismiss will be granted where the plaintiff fails to state a claim upon which relief can be granted. Review is limited to the contents of the complaint. See Clegg Cult Awareness Network, 18 F.3d 752, 754 (9th Cir. 1994). A complaint may be dismissed as a matter of law for one of two reasons: "(1) lack of a cognizable legal theory, or (2) insufficient facts under a cognizable legal claim." Robertson v. Dean Witter Reynolds; Inc., 749 F.2d 530, 534 (9th Cir. 1984) (citation omitted). Allegations of fact in the complaint must be taken as true and construed in the light most favorable to the plaintiff. See Livid Holdings Ltd. v. Salomon Smith Barney, Inc., 416 F.3d 940, 946 (9th Cir. 2005). 9 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 10 of 31 PagelD #: 596 A complaint need not include detailed facts to survive a Rule 12(b)(6) motion to dismiss. See Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555-56 (2007). In providing grounds for relief, however, a plaintiff must do more than recite the formulaic elements of a cause of action. See id. at 556-57; see also McGlinchy v. Shell Chem. Co., 845 F.2d 802, 810 (9th Cir. 1988) ("[C]onclusory allegations without more are insufficient to defeat a motion to dismiss for failure to state a claim.") (citation omitted). "The tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions," and courts "are not bound to accept as true a legal conclusion couched as a factual allegation." Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009) (internal quotations and citations omitted). Accordingly, "[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice." Id. (citing Twombly, 550 U.S. at 555). Rather, "[a] claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Id. at 1949 (citing Twombly, 550 U.S. at 556). Factual allegations that only permit the court to infer "the mere possibility of misconduct" do not show that the pleader is entitled to relief. Id. at 1950. 10 Case 1:1 0-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 11 of 31 PagelD #: 597 A claim may be dismissed under Rule 12 as "barred by the applicable statute of limitations only when `the running of the statute is apparent on the face of the complaint."' Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 969 (9th Cir. 2010) (quoting Huynh v. Chase Manhattan Bank, 465 F.3d 992, 997 (9th Cir. 2006)). Such motion should be granted "only if the assertions of the complaint, read with the required liberality, would not permit the plaintiff to prove that the statute was tolled." Morales v. City of Los Anggles, 214 F.3d 1151, 1153 (9th Cir. 2000) (citation omitted). DISCUSSION Defendants move to dismiss the SAC on the ground that Plaintiffs' claims are barred by the statute of limitations. Defendants further argue that Plaintiffs have not alleged facts to support the application of equitable estoppel and that Plaintiffs' attempts to name Itliong as a defendant do not comply with the Rule 16 Scheduling Order in this case and fall outside the statute of limitations. As a preliminary matter, the Court notes that a rp o se litigant's pleadings must be read more liberally than pleadings drafted by counsel. Wolfe v. Strankman, 392 F.3d 358, 362 (9th Cir. 2004). When a plaintiff proceeds rp o se and technically violates a rule, the court should act with leniency toward the rp o se litigant. Draper v. Coombs, 792 F.2d 915, 924 (9th Cir. 1986). However, "a rp o se 11 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 12 of 31 PagelD #: 598 litigant is not excused from knowing the most basic pleading requirements." American Ass'n of Naturopathic Physicians v. Hayhurst, 227 F.3d 1104, 1107-08 (9th Cir. 2000) (citations omitted). Moreover, "[p]ro se litigants must follow the same rules of procedure that govern other litigants." King v. Atjyeh, 814 F.2d 565, 567 (9th Cir. 1987). L Statute of Limitations "`For actions under 42 U.S.C. § 1983 . . . courts apply the forum state's statute of limitations."' Canatella v. Van De Kamp, 486 F.3d 1128, 1132 (9th Cir. 2007) (quoting Jones v. Blanas, 393 F.3d 918, 927 (9th Cir. 2004)); see also Fink v. Shelder, 192 F.3d 911, 914 (9th Cir. 1999) (same). Although state law determines the statute of limitations, federal law determines when the cause of action accrues. Pesnell, 543 F.3d at 1043 (citing Papa, 2831 F.3d at 1009); see also Cederquist, 235 F.3d at 1156. In the Ninth Circuit, "a claim accrues under federal law when the plaintiff knows or has reason to know of the actual injury." Lukovsky v. San Francisco, 535 F.3d 1044, 1051 (9th Cir. 2008) (citing Inlandboatmens Union of Pac. v. Dutra Group, 279 F.3d 1075, 1081 (9th Cir. 2002)); cf. Wallace v. Kato, 549 U.S. 384, 384 (2007) ("[T]he accrual date of a § 1983 cause of action is a question of federal law that is not resolved by reference to state law."). However, tolling provisions for § 1983 claims are borrowed from 12 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 13 of 31 PagelD #: 599 the forum state. Canatella, 486 F.3d at 1132. Therefore, Hawaii's two-year statute of limitations for personal injury actions applies to Plaintiffs' § 1983 claims. See Haw. Rev. Stat. § 657-7 ("Actions for the recovery of compensation for damage or injury to persons or property shall be instituted within two years after the cause of action accrued."). To the extent that Plaintiffs assert a state law negligence claim, that claim is also governed by the two-year statute of limitations in section 657-7. Plaintiffs filed the instant action on December 15, 2010. (See Doc. # 1.) The large majority of Defendants' alleged misconduct happened between April 2008 and December 12, 2008, when Andrews was arrested. (SAC ¶¶ 27-82.) The very last instance of alleged misconduct occurred on December 14, 2008, the day on which Plaintiff was released from custody. Thus, at the latest, the alleged claims accrued on December 14, 2008, as Plaintiff"kn[ew] or ha[d] reason to know of the actual injury" underlying his claims. Lukovsky, 535 F.3d at 1051. Accordingly, the statute of limitations on Plaintiffs' causes of action expired on December 14, 2010—one day before Plaintiffs filed their Complaint. (See Doc. # 1.) Plaintiffs do not dispute that they filed their Complaint after the statute of limitations expired. However, Plaintiffs assert in their SAC that Hawaii's discovery rules "toll" the statute of limitations, and that Hawaii's 13 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 14 of 31 PagelD #: 600 fraudulent concealment statute and the doctrine of equitable estoppel bar Defendants from asserting the statute of limitations as a defense. (SAC ¶¶ 85-89.) Plaintiffs assert in the SAC that they "suspected that they had a Section 1983 claim and diligently tried to discover information about their claim and were stonewalled by Defendants HAWAII COUNTY's and Mahuna's suppression of the police records." (SAC ¶ 85.) Plaintiffs also assert that Defendants Makua, Ruffolo, Fuiava, Itliong, Miller and others "fraudulently concealed and covered up the basic facts of Plaintiffs' Section 1983 claim." (Id. ¶ 87.) According to Plaintiffs, these Defendants "fraudulently, unconstitutionally concealed exculpatory information from the probable cause analysis using an investigative handoff procedure in violation of the Fourth Amendment, and the fraudulent, unlawful procedure also served to fraudulently conceal personal liability for Plaintiffs[`] Section 1983 claims." (Id.) Plaintiffs further allege that they were "affirmatively misled by misstatements, intended to cover-up unlawful motive and personal liability for the arrest and detention . . . as to what actually happened and who was responsible" for Andrews' arrest. (Id.) Finally, Plaintiffs claim that it was impossible to develop their case further without police records. Defendants argue that none of the causes of action pled in the SAC 14 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 15 of 31 PagelD #: 601 require information that Plaintiffs assert they did not have prior to the expiration of the statute of limitations. Defendants also argue that Plaintiffs do not show that they were lulled into inaction or were prevented from filing a complaint asserting the causes of action pled in the SAC. A. Discovery Rule Plaintiffs state in their Opposition that the "first cause of action may be tolled under Hawaii's discovery rule because there were hidden and latent injury [sic] that took time to discover." (Opp'n at 3.) Plaintiffs appear to refer to Andrews alleged fainting episodes in January and April 2009 as a result of the conditions of his confinement. (Id. at 4.) This allegation is not included in the SAC; however, even if it was, it would not prevent Plaintiffs' first cause of action from being time-barred. Plaintiffs' first cause of action in their SAC is labeled: "Fourteenth Amendment Right—Special Duty to Provide Medical Care to Detainees and Negligence Under State Law Claim." (SAC at 24.) The Court liberally construes Plaintiffs' first cause of action as alleging both a § 1983 claim and a negligence claim. The Due Process Clause of the Fourteenth Amendment guarantees a pretrial detainee the right to receive adequate medical care, and that right is violated if 15 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 16 of 31 PagelD #: 602 officials are deliberately indifferent to the detainee's serious medical needs. Clouthier v. Cnty. of Contra Costa, 591 F.3d 1232, 1242-43 (9th Cir. 2010). The Hawaii state discovery rule provides that "under the statute of limitations currently codified in HRS § 657-7, a cause of action does not `accrue' and the limitations period does not begin to run, until the plaintiff knew or should have known of the defendant's negligence." Hays v. City and County of Honolulu, 917 P.2d 718, 720 (Haw. 1996). First, the discovery rule does not apply to Plaintiffs' § 1983 claim. As discussed above, when a § 1983 claim accrues is a question of federal law, not state law. Wallace, 549 U.S. at 384 ("[T]he accrual date of a § 1983 cause of action is a question of federal law that is not resolved by reference to state law.") In any event, Hawaii's "discovery rule," which would apply to a state negligence claim, is nearly identical to the federal test for determining when a cause of action accrues. See Lukovsky, 535 F.3d at 1051 (noting "a claim accrues under federal law when the plaintiff knows or has reason to know of the actual injury"). Here, Plaintiffs allege that on December 12, 2008, police arrested Andrews from his hospital bed, disrupted his medical treatment, and took him to the Hilo holding cell and did not respond to his repeated statements that he thought he was about to have a heart attack. (SAC ¶¶ 71, 74.) Plaintiffs allege that "most 16 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 17 of 31 PagelD #: 603 likely" Andrews experienced a heart attack that day. (Id. ¶ 77.) Plaintiffs also allege that he received none of the recommended care that hospital doctors had prescribed, that his "health worsened under the harsh conditions in the jail," and that he was showing signs of distress when he returned to the hospital on December 13, 2012. (Id. ¶ 79.) Based on these allegations, Plaintiffs should have been aware that Andrews suffered an actual injury with respect to medical care claim the weekend that he was incarcerated. Therefore, Plaintiffs' assertion that there were "hidden and latent" injuries that took time to discover does not postpone the running of the limitations period for their first cause of action. B. Equitable Relief Plaintiffs also allege that the doctrine of equitable estoppel applies. Equitable estoppel involves a circumstance in which a defendant is estopped from asserting the statute of limitations as a defense. Pursuant to this doctrine, "`a defendant cannot avail [her or] himself of the bar of the statute of limitations, if it appears that he [or she] has done anything that would tend to lull the plaintiff into inaction, and thereby permit the limitation prescribed by the statute to run against him [or her]."' Vidinha v. Miyaki, 145 P.3d 879, 885 (Haw. App. 2006) (quoting Mauian Hotel, Inc. v. Maui Pineapple Co., 481 P.2d 310, 315 (Haw. 1971). "One invoking equitable estoppel must show that he or she has detrimentally relied on 17 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 18 of 31 PagelD #: 604 the representation or conduct of the person sought to be estopped, and that such reliance was reasonable." Id. (quoting Doherty v. Hartford Ins. Group, 574 P.2d 132, 134-35 (Haw. 1978). In their Opposition, Plaintiffs allege that despite repeated requests for police records, Plaintiffs could only obtain a copy of the bail receipt and copies of the recorded 911 calls, "which contained contradictory statements which Plaintiffs relied on, and did not justify filing suit." (Opp'n at 4.) Plaintiffs do not provide facts showing how the bail receipt contained contradictory statements that Plaintiffs relied on. Plaintiffs also appear to assert that they relied on misstatements by Kanaeholo and Ruffolo in recordings of 911 calls and dispatches, although the SAC does not include such allegations. (Opp'n at 7.) However, Andrews' Declaration attached to the SAC states that Andrews received copies of 911 call recordings and radio transmissions, and that he "relied" on Kanaeholo's "recorded intentional misstatements" that she dispatched the details of his 911 call reporting Lewis' alleged assault and that police were responding. (Andrews' Decl. ¶ 9.) Andrews also asserts that he relied on Ruffolo's misstatements to Kanaeholo that "no one is getting arrested" and "we're going to take Mr. Andrews' statement and stuff." (Id.) It is unclear to the Court how such representations could "dissuade Plaintiffs from filing suit." There is no indication that Kanaeholo and 18 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 19 of 31 PagelD #: 605 Ruffolo made these alleged misstatements to Plaintiffs. Moreover, it is not clear how Plaintiffs could have reasonably relied on such alleged misstatements when, according to Plaintiffs' own pleadings, no officer ever responded to Plaintiffs' calls asking for police assistance, the recordings allegedly included Kanaeholo's expressions of"discriminatory bias" against Andrews, and Andrews was in fact arrested. Plaintiffs also assert in their Opposition that Fuiava and Makua made misstatements intended to deceive Plaintiffs about the facts surrounding Andrews' arrest. (Opp'n at 7.) Plaintiffs allege that Fuiava "affirmatively deceived" Plaintiffs after police arrested Andrews at the hospital when, after Rohr asked Fuiava if Andrews was being taken to the police station for questioning, Fuiava responded that "he did not know, that he was only acting on an APB to arrest [Andrews] and call detectives." (SAC ¶ 73.) As this Court stated in its previous Order (see Doc. # 56 at 16), there is no factual allegation in the SAC suggesting that this alleged misrepresentation is false. Moreover, it is not clear how this representation served to dissuade Plaintiffs from filing suit, and there is no allegation in the SAC referencing Plaintiffs' reliance on any misstatements made by Makua. 19 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 20 of 31 PagelD #: 606 In their Opposition, Plaintiffs rely in large part on Kamruddin v. Desmond, 293 A.D.2d 714 (N.Y. A.D. 2002). In Kamruddin, a medical malpractice plaintiff demanded copies of his medical records from the defendants, who did not produce the records until a day before the statute of limitations expired. Id. at 714. The court affirmed the lower court's decision that the defendants were equitably estopped from asserting a statute of limitations defense, stating that "[w]here a medical malpractice claim is asserted, the patient's medical records are material to reaching a responsible decision on whether there is grounds for a lawsuit." Id. at 715. Plaintiffs appear to argue that the instant case is analogous to Kamruddin because in November 2011, after Plaintiffs filed their First Amended Complaint, Defendants allegedly provided Plaintiffs with requested discovery material including a copy of the application and Order for Probable Cause Determination for Further Detention that identified Itliong as applicant/affiant and Ruffolo as "author of the APB upon which he had relied." (Opp'n at 12.) In an attempt to draw similarities with the instant case, Plaintiffs assert that "[1]ike in the Kamruddin case, here a false arrest and false imprisonment claim is asserted, therefore the judicial Order for Probable Cause For Further Detention is material to reaching a responsible decision on whether there are grounds for a lawsuit." 20 Case 1:1 0-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 21 of 31 PagelD #: 607 (Opp'n at 13.) Plaintiffs further assert that Defendants' "intentional delay" in producing a copy of the judicial order and other "material" police records constitutes intentional misconduct that prevented Plaintiffs from timely commencing the instant action and precludes Defendants from asserting a statute of limitations defense. (Opp'n at 13.) The Court is not persuaded. First, Kamruddin, a New York state court case, involves medical malpractice, not a false arrest and imprisonment claim. See 293 A.D.2d 714. Second, it is not clear how an application and judicial order for probable cause is material to Plaintiffs' decision whether to file suit. Indeed, Plaintiffs asserted a false arrest claim in their original Complaint and First Amended Complaint before Plaintiffs allegedly received the judicial order and police records. (See Docs. # 1, 41.) Plaintiffs state in their Opposition that although they filed "what they believed to be true facts" in their original Complaint, they "were precluded from filing a correct account of the facts [] because of HPD and Hawaii County's intentional misconduct." (Opp'n at 13.) However, Plaintiffs' original Complaint contains allegations of Andrews' arrest at the hospital, including that the arrest was without probable cause, and officers' disregard of Andrews' requests for medical attention. (See Doc. # 1 ¶ 52-72.) Plaintiffs do not explain the contents of the application or judicial 21 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 22 of 31 PagelD #: 608 order, except to say that the application identifies Itliong and Ruffolo. To the extent that Plaintiffs argue that Defendants concealed Itliong's alleged involvement, Plaintiffs' contention fails. Plaintiffs assert that Defendants Makua, Ruffolo, Fuiava, Itliong, Miller, and others used an "investigative handoff procedure" that "served to fraudulently conceal personal liability for Plaintiffs['] Section 1983 claims." (SAC ¶ 87.) Plaintiffs' allegation regarding the "investigative hand-off procedure" appears to refer to certain Defendants' passing of Andrews' case "to a new investigative group—the detectives in Criminal Investigative Section." (SAC ¶ 69.) However, it is unclear, and Plaintiffs do not explain beyond conclusory assertions, how the "investigative hand-off procedure" fraudulently concealed personal liability and how Plaintiffs detrimentally relied on it. Andrews' Declaration indicates that the first time Plaintiffs asked police about a probable cause document during the statute of limitations period was between November 29, 2010 and December 15, 2010, when Rohr went to the police records division and asked the custodian of records, Lieutenant Randal Ishii, Andrews' Declaration identifies this date as November 29, 2008. (Andrews Decl. ¶ 7.) However, it appears that Andrews actually meant to cite November 29, 2010, as Andrews' alleged incarceration occurred the weekend of December 12, 2008, and Plaintiffs repeatedly refer to November 29, 2010 as when they received the hospital report, discussed infra. 22 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 23 of 31 PagelD #: 609 whether there was "an APB, any probable cause affidavit or warrant of any Insane Suspect report for the case." (Andrews Decl. ¶ 7.) According to Plaintiffs, Ishii "appeared to looked [sic] at his computer and said there were none in their records." (Id.) Plaintiffs also proffered an October 20, 2011 letter from the police department referencing a September 7, 2011 request for reports and other materials and referring the request to the Corporation Counsel because of Plaintiffs' pending civil lawsuit against Defendants. (FAC Ex. A.) These instances do not amount to affirmative misconduct that would lull Plaintiffs into inaction. At the hearing, Plaintiffs directed the Court's attention to Estate of Amaro III v. City of Oakland, in which the Ninth Circuit—answering a question certified by the district court—held that the doctrine of equitable estoppel does apply where a plaintiff believes she has a 1983 claim but is dissuaded from bringing the claim by affirmative misrepresentations and stonewalling by the police. 653 F.3d 808, 809, 815 (9th Cir. 2011). In Amaro, Jerry Amaro was beaten severely by police during an arrest and was denied treatment while in custody. Id. at 810. Amaro told his mother, Geraldine Montoya, what happened and died days later. Id. A police officer told Montoya that Amaro "died in the street" in a gang dispute, although Amaro died at a friend's home and the officer had already received information corroborating Montoya's contention that police 23 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 24 of 31 PagelD #: 610 beat Amaro. Id. at 811. Police denied Montoya's requests for copies of the police report for the arrest as well as records related to the investigation of his death; her requests were first denied on the basis that the matter was still "under investigation," but police continued to deny her requests even after the homicide investigation was completed. Id. Montoya was never informed of the results of the homicide investigation or a police internal affairs investigation that found, inter alia, that Amaro was severely injured during his arrest and that use of force against Amaro was left out of the police report. Id. at 812. Montoya also met with five different lawyers, who told her that, in light of Amaro's uncorroborated statements about a police beating and the police officer's (mis)statements regarding his death, she did not have sufficient evidence to file a § 1983 claim. The allegations in the instant case simply do not rise to the level of that in Amaro. Plaintiffs' assert in the SAC that they were denied access to police records and that the police department disciplined "certain defendants" but that Plaintiffs were denied access to the named defendants' disciplinary records. (SAC ¶ 4.) However, Plaintiffs' general statement in the SAC that they were denied access to police records does not show that Defendants affirmatively and 2 Plaintiffs assert that the exhibits attached to their FAC show that they "diligently pursued information about our Section 1983 claim but have been stonewalled and refused copies of the police records." (Andrews Decl. ¶ 6.) 24 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 25 of 31 PagelD #: 611 fraudulently concealed information necessary for Plaintiffs to understand the true facts. Moreover, Plaintiffs have not sufficiently alleged that Defendants made any affirmative misrepresentations that Plaintiffs would reasonably rely on and would lull them into inaction.' Plaintiffs also assert that they investigated their case with "reasonable diligence" and that it was not until November 29, 2010 that: Plaintiffs discovered the true facts surrounding Plaintiff ANDREWS' arrest in notes in a hospital report which exposed the falsity of misleading statements made by Defendants FUTAVA and MAKUA to Plaintiffs and made Plaintiffs see the case in a totally new way Defendants FUTAVA and MAKUA were not innocents acting on an APB but investigators; they had interviewed hospital staff and asked However, the exhibits do not show that police repeatedly refused requests for the same police records during the statute of limitations period. The police correspondence Plaintiffs proffer includes three letters from the police declining to release police reports; all three letters reference different police reports and cite pending or possible investigation or prosecution as the reason for not producing the reports. (FAC Ex. A.) 3 For these reasons, Plaintiffs' allegations also fall short of federal standards for equitable estoppel. See Estate of Amaro v. City of Oakland, 653 F.3d 808, 813 (9th Cir. 2011) ("In this circuit, the plaintiff carries the burden of pleading and proving the following elements of equitable estoppel: (1) knowledge of the true facts by the party to be estopped, (2) intent to induce reliance or actions giving rise to a belief in that intent, (3) ignorance of the true facts by the relying party, and (4) detrimental reliance. Additionally, when estoppel is sought against the government, `there must be affirmative misconduct (not merely negligence) and a serious injustice outweighing the damage to the public interest of estopping the government."' (citation omitted)). 25 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 26 of 31 PagelD #: 612 them to certify a civil commitment procedure to permanently discredit Plaintiff ANDREWS indicating First Amendment retaliation, and failed; there was deliberate interference with and delay of Plaintiff ANDREWS' medical care; the information gained by the interview and failed civil commitment dissipated probable cause to arrest Plaintiff ANDREWS; and there was a pattern of investigation hand- offs used to conceal identities of the persons culpable for the arrest and what they did to cause it. (Opp'n at 5.) Plaintiffs further assert that they did not know who was culpable for Andrews' arrest or how they caused it until seeing this November 2010 report. (Opp'n at 11.) To the extent that Plaintiffs may be referencing this report to assert equitable tolling, Plaintiffs fail. Equitable tolling involves the suspension of the running of the limitations period. "In order to toll a statute of limitations for a complaint filed after its expiration, a plaintiff must demonstrate (1) that he . . . has been pursuing his right diligently, and (2) that some extraordinary circumstance stood in his way." Office of Hawaiian Affairs v. State, 122 P.3d 767, 789 (Haw. 2006) (internal quotations omitted). "Extraordinary circumstances are circumstances that are beyond the control of the complainant and make it impossible to file a complaint within the statute of limitations." Id. Plaintiffs still fail to allege sufficient facts showing that how the absence of this report made it impossible for Plaintiffs to file their claims within 26 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 27 of 31 PagelD #: 613 the statute of limitations. Moreover, Plaintiffs' description of the report and how it "made Plaintiffs see the case in a totally new way" largely comprises conclusory recitations of their causes of action. Accordingly, the Court concludes that Plaintiffs have failed to allege sufficient facts in the SAC to show that Plaintiffs are entitled to equitable relief. C. Fraudulent Concealment Plaintiffs also contend that Hawaii's "fraudulent concealment" statute should toll the statute of limitations. Hawaii Revised Statutes § 657-204 provides: If any person who is liable to any of the actions mentioned in this part or section 663-3, fraudulently conceals the existence of the cause of action or the identity of any person who is liable for the claim from the knowledge of the person entitled to bring the action, the action may be commenced at any time within six years after the person who is entitled to bring the same discovers or should have discovered, the existence of the cause of action or the identity of the person who is liable for the claim, although the action would otherwise be barred by the period of limitations. Haw. Rev. Stat. § 657-20. As used in § 657-20, fraudulent concealment means the "employment of artifice, planned to prevent inquiry or escape investigation, and [mislead] or hinder acquirement of information disclosing a right of action." See Au v. Au, 626 P.2d 173, 178 (Haw. 1981) (quotation and citation signals omitted); 4 Plaintiffs cite Haw. Rev. Stat. § 657-22 as "Hawaii's fraudulent concealment statute." (SAC ¶ 89.) However, as § 657-22 is inapplicable, the Court construes Plaintiffs' assertion as one under § 657-20. 27 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 28 of 31 PagelD #: 614 see also Gast v. Kwak, 396 F. Supp. 2d 1150, 1157 (D. Haw. 2005) (applying H.R.S. § 657-20); Nakamoto v. Hartley, 758 F. Supp. 1357, 1364-65 (D. Haw. 199 1) (citing Au and applying HRS § 657-20). In other words, fraudulent concealment requires that a plaintiff show that a defendant acted affirmatively and fraudulently to conceal the cause of action. See Au, 626 P.2d at 178; Gast, 396 F. Supp. 2d at 1157. Au states that [i]t is not necessary that a party should know the details of the evidence by which to establish his cause of action. It is enough that he knows that a cause of action exists in his favor, and when he has this knowledge, it is his own fault if he does not avail himself of those means which the law provides for prosecuting or preserving his claim. Au, 626 P.2d at 178 (citation and quotations signals omitted). Importantly, the Hawaii Supreme Court has stated that the "fraudulent concealment which will postpone the operation of the statute must be the concealment of the fact that plaintiff has a cause of action. If there is a known cause of action there can be no fraudulent concealment." Id. at 173 (citations omitted) (emphasis in original). Plaintiffs have not alleged any facts showing that Defendants withheld information that Plaintiffs needed to understand that they had a cause of action. As discussed above, Plaintiffs' general statements that they were denied access to police records does not show that Defendants affirmatively and fraudulently concealed information necessary for Plaintiffs to understand that they had a cause 28 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 29 of 31 PagelD #: 615 of action. Plaintiffs' conclusory and unclear assertions about Defendants' "investigative hand-off procedure," do not sufficiently demonstrate how this alleged concealment, whatever it may be, hindered Plaintiffs' ability to obtain information disclosing their right of action. Plaintiffs' allegations surrounding the application and order for probable cause do not rise to the level of affirmative and fraudulent concealment of the fact that Plaintiffs have a cause of action; as noted above, Plaintiffs filed an FAC before they received this information. See Au, 626 P.2d at 178 ("If there is a known cause of action there can be no fraudulent concealment."). Accordingly, based on Plaintiffs' allegations, Hawaii's fraudulent concealment statute does not provide Plaintiffs relief. IV. Leave to Amend Pursuant to Rule 15(a)(2), courts should "freely give leave [to amend] when justice so requires." Further, "requests for leave should be granted with extreme liberality." Moss v. U.S. Secret Service, 572 F.3d 962, 792 (9th Cir. 2009). "Dismissal without leave to amend is improper unless it is clear . . . that the complaint could not be saved by an amendment." Id. "However, `liberality in granting leave to amend is subject to several limitations."' Cafasso; U.S. ex rel. v. Gen. Dynamics C4 Sys., 637 F.3d 1047, 1058 (9th Cir. 2011) (quoting Ascon Props.; Inc. v. Mobil Oil Co., 866 F.2d 1149, 1160 (9th Cir. 1989)). "Those 29 Case 1:10-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 30 of 31 PagelD #: 616 limitations include undue prejudice to the opposing party, bad faith by the movant, futility, and undue delay." Id. (citing Ascon Props, 866 F.2d at 1160). "Further, `[t]he district court's discretion to deny leave to amend is particularly broad where plaintiff has previously amended the complaint."' Id. (quoting Ascon Props, 866 F.2d at 1160). Here, it is beyond dispute that the statute of limitations on Plaintiffs' claims expired before they filed their Complaint. Plaintiffs have now been allowed two opportunities to amend their complaint and allege sufficient grounds for equitable relief to address Defendants' statute of limitations defense. As Plaintiffs have failed to do so, the Court concludes that any further amendment will be futile. The Court also notes that it notified Plaintiffs in its February 9, 2012 order that failure to cure the pleading deficiencies would result in dismissal of the action with prejudice. The Complaint is therefore DISMISSED as against all Defendants in this action. CONCLUSION For these reasons, the Court GRANTS Defendants' Motion to Dismiss. H H 30 Case 1:1 0-cv-00749-DAE-KSC Document 78 Filed 06/29/12 Page 31 of 31 PagelD #: 617 IT IS SO ORDERED. DATED: Honolulu, Hawaii, June 29, 2012. David an fia United Statd§M5istrict Judge Andrews, et al. v. County of Hawaii et al., Cv. No. 10-00749 DAE-KSC; ORDER GRANTING DEFENDANTS' MOTION TO DISMISS 31