Unreported / Non-Citable
Background
Joseph Lamantia, a former Modesto police officer, alleged that on December 29, 2020 he shot and killed an individual in an officer-involved shooting. Stanislaus County District Attorney Birgit Fladager announced a voluntary manslaughter charge against him in March 2021. Lamantia alleged that an expert retained by Fladager concluded his actions complied with department policy and the shooting was justified, yet the prosecution continued. He further alleged that investigator John Locke prepared a competing report from an improper hindsight perspective under Fladager's direction and later under Jeff Laugero, who succeeded Fladager as district attorney. The state superior court dismissed all charges against Lamantia on July 21, 2023.
Lamantia initiated the action in Stanislaus County Superior Court on July 10, 2024 and filed the operative first amended complaint on August 5, 2024. The County, Fladager, Laugero, and Locke removed the case to federal court. The complaint asserted eighteen causes of action, including Section 1983 claims against the County based on unconstitutional custom or policy, failure to train, and ratification; supervisory and abuse-of-process claims against the individual defendants; and state-law claims for intentional infliction of emotional distress and negligence. Lamantia sought general and special damages, punitive damages, attorneys' fees, and costs.
Defendants moved under Federal Rule of Civil Procedure 12(c) for judgment on the pleadings as to all eighteen claims. The motion was taken under submission on the papers on November 18, 2025. The court accepted the complaint's factual allegations as true and applied the same standard used for a Rule 12(b)(6) motion. The order was signed November 3, 2026 and filed November 4, 2026.
The Court’s Holding
The court dismissed claims one through eight against the County. It explained that a California district attorney acts as a state official, not a county one, when deciding whether to prosecute. Although Lamantia characterized some allegations as fabrication-of-evidence claims, the court found the counts were premised on alleged unconstitutional policies that led Fladager and Laugero to charge and continue prosecuting him, so the County was not the proper municipal defendant. The court treated Lamantia's failure to address this argument as a concession but independently found defendants' position persuasive, and it did not reach defendants' remaining arguments on these claims.
Claims nine through fourteen, brought against Fladager, Laugero, and Locke in their official capacities, were also dismissed. The court found them substantively indistinguishable from the claims against the County and grounded in the same investigation and prosecution allegations. Because the defendants functioned as state officers in that context, official-capacity claims seeking monetary damages were barred by Eleventh Amendment sovereign immunity, and the court declined to address the remaining arguments concerning these claims.
After dismissing all claims over which it had original jurisdiction, the court declined supplemental jurisdiction over claims fifteen through eighteen under 28 U.S.C. § 1367(c), denied defendants' motion as to those claims as moot, and remanded them to the Stanislaus County Superior Court to determine whether they are subject to dismissal. In footnote 6 the court stated that California Government Code § 821.6 'would therefore bar these claims' and noted that plaintiff never addressed that argument in opposition, but the operative order left any dismissal to the state court. Claims one through fourteen were dismissed without leave to amend because amendment would be futile, and the Clerk was directed to close the case.
Key Takeaways
- The court held that the County could not be liable on the pleaded prosecution-based Section 1983 theories because California district attorneys act as state officers when charging and prosecuting.
- Official-capacity damages claims against the district attorneys and the investigator were dismissed on Eleventh Amendment grounds because they arose from the same state prosecution-related conduct.
- The dismissal of claims one through fourteen was without leave to amend because the court found those claims nonviable as a matter of law and amendment futile.
- The four remaining state-law claims were not dismissed on the merits; the federal court declined supplemental jurisdiction, denied the motion as moot, and remanded them to state court.
- Footnote 6 stated that Government Code § 821.6 'would therefore bar' the remanded claims and noted plaintiff's failure to address that argument, but the operative order left the dismissal decision to the Stanislaus County Superior Court.
Why It Matters
The order separates the identity of the governmental actor from the label placed on a constitutional claim. Even though Lamantia described fabricated evidence and investigative misconduct, the court examined the foundation of the pleaded counts and concluded they challenged policies producing charging and continued-prosecution decisions. That characterization defeated the County claims and supported sovereign immunity for the official-capacity damages claims.
The disposition is also important for what it left open. The federal court ended the federal case and closed its docket, but its operative paragraphs remanded claims fifteen through eighteen for the state court to determine whether they are subject to dismissal. The footnote's statement that § 821.6 'would therefore bar' those claims signals the federal court's view of their viability without entering a merits judgment.