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Shadle v. City of Corona

Citations: 96 Cal. App. 3d 173; 157 Cal. Rptr. 624; 1979 Cal. App. LEXIS 2054Docket: Civ. 20563

Court: California Court of Appeal; August 21, 1979; California; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by the plaintiff against a summary judgment favoring the City of Corona and its police officers in a malicious prosecution and false arrest claim. The plaintiff was arrested for attempting to receive stolen property after an informant, under police instruction, set up a purchase of stolen guns. Although acquitted at trial, the plaintiff alleged a conspiracy to falsely arrest and prosecute him. The defendants filed for summary judgment, which the court granted after denying the plaintiff's late counterdeclarations. The plaintiff argued that the local filing rule was inconsistent with state law, but the court upheld the rule, emphasizing procedural compliance. The ruling was based on the absence of a triable issue of fact regarding conspiracy and the determination that the defendants acted in good faith. Additionally, the court found no conflict between the local rule and state procedural statutes, and the plaintiff's failure to seek remedy under Code of Civil Procedure section 473 precluded further appeal on filing issues. The judgment was affirmed, supporting the defendants' actions as lawful and justified under the circumstances.

Legal Issues Addressed

Conspiracy and Vicarious Liability in False Arrest Claims

Application: The defendants successfully negated the existence of a conspiracy claim, as there was no triable issue of fact suggesting vicarious liability.

Reasoning: The defendants provided evidence negating the existence of a conspiracy, indicating that Steele and Boardwell believed the plaintiff thought the guns were stolen.

Local Court Rules and Filing Deadlines

Application: The court adhered to local filing rules requiring documents to be submitted days before a hearing, ruling that these procedural rules were not in conflict with state law.

Reasoning: Paragraph 7 of the memorandum, amended on March 7, 1977, stipulates that supplemental documents for a law and motion matter must be filed with the Clerk of Court at least 5 court days before the hearing, while opposing documents must be filed at least 3 court days prior.

Probable Cause and Good Faith in Criminal Attempt Charges

Application: The court found that the defendants acted in good faith based on credible informant information, leading to plaintiff's arrest for attempting to receive stolen property.

Reasoning: There is no evidence suggesting Steele or Boardwell were aware of any prior statements from Skaggs denying the guns were stolen, negating claims of bad faith conspiracy.

Procedural Impropriety and Appeals

Application: The court ruled that the plaintiff's failure to file a motion under Code of Civil Procedure section 473 precluded appeal on the basis of excusable neglect.

Reasoning: If the plaintiff argues ignorance due to excusable neglect, the proper remedy is a motion under Code of Civil Procedure section 473; without such a motion, the issue is not subject to appeal.

Summary Judgment Standards

Application: The court granted summary judgment in favor of defendants based on declarations and records, and the denial of plaintiff's late counterdeclarations.

Reasoning: The court denied Shadle's attorney's request to submit counterdeclarations, citing a late filing. The court granted the defendants' motion, leading to this appeal.