Oakland Jury Awards $5 Million to Sonoma County Man for Wrongful Arrest
A California Highway Patrol officer and sergeant must pay $5 million to a Sonoma County man for violating his constitutional rights in an unlawful arrest, an Oakland federal jury decided Monday.
The jury found that CHP Officer Jayce Ray and Sgt. John Snider acted with “malice, recklessness, oppression or a conscious or reckless disregard” for the rights of Nicholas La Motte when they arrested him without probable cause in April 2023 for driving under the influence.
La Motte testified last week that around 1:30 a.m. on April 25, 2023, he was driving home from visiting his grandmother in San Francisco. While driving northbound on U.S. 101, he noticed he was being followed by a car — it was Ray in his cruiser.
Ray pulled him over, and La Motte began filming the encounter, footage that proved to key in his case against CHP.
Ray impounded La Motte’s Mercedes and arrested him, claiming he showed signs of intoxication, including red eyes. He then took La Motte to a nearby hospital to have his blood drawn. La Motte argued in his lawsuit that this violated his constitutional rights against unnecessary search and seizure because Ray lacked probable cause for the arrest.
CHP further justified La Motte’s arrest with a set of field sobriety tests that Snider administered at the Santa Rosa station.
Six months later, the Sonoma County District Attorney’s Office formally dropped charges against La Motte.
The jury’s verdict is significant because law enforcement and other government officials are generally protected from liability while on the job, under a legal framework known as qualified immunity. They lose that protection, however, if they violate someone’s rights while performing their duties.
That’s what the jury found happened here.
Izaak Schwaiger, La Motte’s attorney, said that, had his client not recorded the incident, there wouldn’t have been any evidence to combat the police’s version of events because CHP doesn’t require its officers to wear body cameras.
“I would say this is probably the 20th case that we received calls about, the CHP in and around the Sonoma County area making false arrests, but there was never any evidence,” Schwaiger said. “And what can you do when it’s the word of the individual against the word of the cops?”
Schwaiger said he took La Motte’s case because he was “waiting for the right one to come, where somebody had done something to preserve some kind of evidence, so that we could prove that this was going on, because it happens a lot.”
“But without proof,” the lawyer continued, “what can you do? Nick had that video, and the video showed that these cops were lying, and that’s what carried the case.”
Schwaiger said La Motte’s case was unique because it was simply about a wrongful arrest.
“The DA rejected this case because there wasn’t enough evidence that he had committed a crime,” Schwaiger said, adding that La Motte wasn’t prosecuted, nor held in jail for a significant time, nor physically beaten by the officers. “None of those things.”
“It was super important to Nick what happened. It profoundly affected his life, and he did a really good job of explaining that to the jury, such that when it came time to ask the jury for a verdict, we just said, ‘Do what you feel is right,’” Schwaiger said.
The jury’s verdict awarded La Motte $3 million in punitive damages — an amount for which Snider and Ray will not likely be personally liable, Schwaiger said — and $2 million in compensatory damages.
“The law says California doesn’t have to cover them,” Schwaiger said. “In practice, it’s highly likely that the state will cover them because there will be a lot of pressure from the police unions and whatnot to do that. And the police unions are quite powerful.”
CHP and the California Department of Justice did not respond to a request for comment.
Robert Weisberg, a Stanford law professor, said a case like La Motte’s doesn’t usually unfold with a jury award because an unlawful arrest is usually challenged in the middle of criminal proceedings, not in a civil case.
“It’s rare that people have the legal resources or the incentive to challenge an arrest in a civil suit like this, and they are very hard to win,” Weisberg said. “Because the most obvious fact is an arrest isn’t illegal simply because it turns out that, in retrospect, there wasn’t probable cause.
“The plaintiff has to prove that, in effect, no reasonable officer in that situation could have surmised that there was probable cause,” Weisberg continued. “And that’s a hard standard to meet.”
In defending the officers, the state called Capt. Lorenzo Glenn of the Anaheim Police Department, who testified that he reviewed the case file and found the officer’s actions to be reasonable. But when questioned by Schwaiger, Glenn admitted he wasn’t an expert in DUI or drug recognition.
“I find it just bizarre that they put on a so-called expert witness who acknowledged that he wasn’t an expert,” Weisberg said. “It’s not that hard to find experts who will testify for the government in this regard.
“The government lawyering in this case was less than impressive, let’s put it that way,” he added.
Weisberg said the case was unusual because the government’s evidence supporting the arrest was weak, La Motte recorded his arrest, and the police weren’t afforded qualified immunity.
“This is like the perfect case for a plaintiff,” he said.
Earlier this year, the California Justice Department, in defense of Ray and Snider, moved to have the case thrown out on the basis of qualified immunity. It lost its appeal of a district judge’s ruling at the 9th Circuit Court of Appeals, which found the state’s petition to be frivolous.
District Judge Araceli Martínez-Olguín denied a similar motion last week after La Motte’s attorneys rested their case, saying the DOJ further failed to bring up qualified immunity earlier in the proceedings.
Schwaiger said La Motte called him Tuesday morning and said that he hoped people would hear about the verdict and take similar action, namely by safely filming interactions with police.
“This was the result of a yearslong process where a man, against all odds, decided to stand up for himself and refused to say that what happened was OK,” Schwaiger said. “There’s an important lesson there, and I think if more people do stand up for themselves, that’s how we really affect change.”