Hale v. County of Los Angeles
Hale v. County of Los Angeles
Opinion of the Court
MEMORANDUM
Plaintiff Dennis Hale appeals the district court’s grant of summary judgment in fa
The district court properly granted summary judgment on the claim of unlawful detention. Probable cause to arrest Plaintiff existed because the available facts suggested a “fair probability” that Plaintiff had committed a crime. See United States v. Hartz, 458 F.3d 1011, 1018 (9th Cir. 2006) (“A police officer has probable cause to arrest a suspect without a warrant if the available facts suggest a ‘fair probability’ that the suspect has committed a crime.”). During an attempt to post bail for a prisoner, Plaintiff presented a Bail Agent Identification Card lacking several indicia of authenticity and bearing an Insurance License number that did not match the number on his Insurance License Card. Under California law, it is a crime to knowingly present false identification, see CaLPenal Code § 529.5(c), to attempt to execute a bail bond unless properly licensed, see Cal. Ins.Code §§ 1800, 1802, 1814, and to falsely represent oneself as a licensed bail agent, see CaLCode Regs. tit. 10, § 2067.
The district court properly grants ed summary judgment on the claim of excessive force. Defendant County cannot be liable for the actions of its police officers unless those actions are taken pursuant to an official “policy or custom.”
We also reject Plaintiffs argument based on City of Canton v. Harris, 489 U.S. 378, 109 S.Ct. 1197, 103 L.Ed.2d 412 (1989), that the policymakers of the city were deliberately indifferent to the need to train its police officers. The record contains no evidence related to Defendant County’s training policies or any alleged deficiencies in training of any police officer. See Blankenhorn v. City of Orange, 485 F.3d 463, 484-85 (9th Cir. 2007) (holding that “absent evidence of a ‘program-
AFFIRMED.
This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3.
. Although Plaintiff brought suit against the individual police officers in addition to Defendant County, he appealed the district court’s ruling only with respect to Defendant County.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.