STEPHENSON vs SACRAMENTO COUNTY SHERIFFS DEPARTMENT, et al.

25CV016139: STEPHENSON vs SACRAMENTO COUNTY SHERIFFS DEPARTMENT, et al. 09/03/2026 Hearing on Motion for Leave to File First Amended Complaint in Department 16C

Tentative Ruling

TENTATIVE RULING: The notice of motion does not provide notice of the Court’s tentative ruling system, as required by Local Rule 1.06(D). Plaintiff in pro per is directed to contact opposing counsel forthwith to advise of Local Rule 1.06, the Court’s tentative ruling procedure, and the manner to request a hearing. If Plaintiff is unable to contact opposing counsel prior to the hearing, Plaintiff shall be available at the hearing, in person or remotely, in the event opposing counsel appears without following the procedures set forth in Local Rule 1.06(B).

Background

Plaintiff in pro per Matthew Stephenson’s (“Plaintiff”) motion for leave to file first amended complaint (“FAC”) is GRANTED. In this action, Plaintiff alleges an inadequate response to his reports of threats and stalking by Defendants Sacramento County and Sacramento County Sheriff’s Office (“Defendants”). Plaintiff commenced this action by filing the operative Complaint on July 3, 2025. Defendants filed their answer on August 27, 2025, and in February 2026 the parties began meeting-andconferring on Defendants’ planned Motion for Judgment on the Pleadings (“MJOP”). (Stephenson Decl., Exh.

B.) In response to the conferrals, Plaintiff prepared a draft FAC. (Ibid.) Defendants apparently refused to stipulate to amendment (see ibid.) and Plaintiff filed this motion for leave to amend on June 24, 2206. Defendants filed their MJOP to the operative complaint on July 10, 2026. Plaintiff contends that leave should be granted because the “proposed amendment narrows the action and proceeds solely on federal constitutional claims” and because amendment will not prejudice Defendants. (Mot. at p. 2.)

Defendants oppose. Defendants’ unopposed request for judicial notice is denied. The Court does not find the requested documents and facts to be relevant to resolving this motion. Legal Standard “The court may, in its discretion, after notice to the adverse party, allow, upon any terms as may be just, an amendment to any pleading.” (Code Civ. Proc., § 473, subd. (a)(1).) A motion to amend a pleading must include a copy of the proposed amended pleading and state what allegations will be deleted or added by page, paragraph, and line number. (Cal.

Rules of Court, rule 3.1324, subd. (a).) Further, the party must submit a separate declaration specifying “(1) The effect of the amendment; (2) Why the amendment is necessary and proper; (3) When the facts giving rise to the amended allegations were discovered; and (4) The reasons why the request was not made earlier.” (Id., subd. (b).) Courts “apply a policy of great liberality in permitting amendments to the complaint at any stage

25CV016139: STEPHENSON vs SACRAMENTO COUNTY SHERIFFS DEPARTMENT, et al. 09/03/2026 Hearing on Motion for Leave to File First Amended Complaint in Department 16C

of the proceedings, up to and including trial.” (Magpali v. Farmers Group, Inc. (1996) 48 Cal.App.4th 471, 487.) This policy ensures that cases are tried and decided on the merits. (Higgins v. Del Faro (1981) 123 Cal.App.3d 558, 565.) The rule of granting leave to amend prevails unless prejudice to the adverse party can be shown. (Higgins, supra, 123 Cal.App.3d at p. 564.) Prejudice is more than that a defendant must merely defend another charge or face additional evidence. (Landis v. Super. Ct. (1965) 232 Cal.App.2d 548, 557; Hirsa v.

Super. Ct. (1981) 118 Cal.App.3d 486, 490.) Prejudice can be found in an unexplained delay that causes trial continuance or where amendment would be futile as a matter of law. (Magpali, supra, 48 Cal.App.4th at p. 486–488; Cal. Casualty Gen. Ins. Co. v. Super. Ct. (1985) 173 Cal.App.3d 274, 280–281, disapproved on other grounds by Kransco v. American Empire Surplus Lines Ins. Co. (2000) 23 Cal.4th 390, 405.)

Discussion

Defendants first argue that Plaintiff failed to comply with Rule 3.1324. Plaintiff’s moving papers provided a copy of the proposed FAC, which rewrites the complaint entirely at much greater length and detail. Plaintiff declares that he seeks leave to amend “in order to clarify and streamline the claims asserted” and that the FAC “removes state-law causes of action and proceeds solely on federal constitutional claims.” (Stephenson Decl. ¶¶ 2, 3.) Plaintiff declares that the “amendment is sought in good faith and not for purposes of delay.” (Id. ¶ 4.)

The Court finds that Plaintiff has minimally complied with Rule 3.1324.[1] Defendants fail to argue any prejudice, much less undue prejudice. (See Opp.) The word “prejudice” does not appear in the opposing papers. (Ibid.) Defendants instead argue that Plaintiff’s claims are barred by statutes of limitations, federal-claim pleading requirements, immunity, or other substantive points of law. In essence, Defendants attempt to convert this motion for leave to amend into their own MJOP. (See Ward Decl. ¶¶ 4–5.)

Indeed, Plaintiff prepared the FAC partly to address Defendants’ points raised during pre-MJOP conferral, as envisioned by statute. (See Code Civ. Proc., § 439, subd. (a); Stepheson Decl., Exh. B.) The Court declines to address the substance of Plaintiff’s claims at this time, which is not generally a ground for denial of a motion for leave to amend. The legal standard on a motion for leave to amend is prejudice. The rule of granting leave to amend prevails unless prejudice to the adverse party can be shown. (Higgins, supra, 123 Cal.App.3d at p. 564.)

While the Court may deny leave to amend where the facts are undisputed and it is clear that no cause of action can be stated as a matter of law, the Court does not find that the proposed amendments present such a circumstance here based on the proposed pleadings and arguments presented by the Parties at this time. (See Komorsky v. Farmers Ins. Exch. (2019) 33 Cal.App.5th 960, 971.) Rather, when the adequacy of the pleadings is unclear, “the proper course of action [is] to permit amendment, after which the defendants [may test] the complaint’s sufficiency via demurrer or motion for judgment on the pleadings.” (Armenta ex rel.

City of Burbank v. Mueller Co. (2006) 142 Cal.App.4th 636, 643.)

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV016139: STEPHENSON vs SACRAMENTO COUNTY SHERIFFS DEPARTMENT, et al. 09/03/2026 Hearing on Motion for Leave to File First Amended Complaint in Department 16C

Defendants have not argued, much less shown, undue prejudice. Accordingly, Plaintiff’s motion is granted. The ruling on this motion is, of course, without prejudice to Defendant’s ability to file any applicable or appropriate motions to test the sufficiency of the pleadings.

Disposition

Plaintiff’s motion for leave to file First Amended Complaint is GRANTED. Plaintiff shall file and serve the proposed FAC no later than September 17, 2026. Although not required by court rule or statute, Plaintiff is directed to present a copy of this order when the amended complaint is presented for filing. Defendants may file and serve a response within 30 days of service of the FAC, 35 days if served by mail. This minute order is effective immediately. No formal order or other notice is required. (Code Civ. Proc., § 1019.5; Cal. Rules of Court, rule 3.1312.)

[1] Plaintiff filed a Supplemental Statement pursuant to Rule 3.1324 with his reply

papers. The Court does not consider these new facts submitted in reply. (Jay v. Mahaffey (2013) 218 Cal.App.4th 1522, 1537–1538.) All papers supporting a motion must be filed at least 16 court days before the hearing. (Code Civ. Proc., § 1005, subd. (b).)

NOTICE:

Consistent with Local Rule 1.06(B), any party requesting oral argument on any matter on this calendar must comply with the following procedure:

To request limited oral argument, on any matter on this calendar, you must call the Department 16C Oral Argument Request Line at (916) 874-1475 by 4:00 p.m. the Court day before the hearing and advise opposing counsel. At the time of requesting oral argument, the requesting party shall leave a voice mail message: a) identifying themselves as the party requesting oral argument; b) indicating the specific matter/motion for which they are requesting oral argument; and c) confirming that it has notified the opposing party of its intention to appear and that opposing party may appear via Zoom using the Zoom link and Meeting ID indicated below. If no request for oral argument is made, the tentative ruling becomes the final order of the Court.

Unless ordered to appear in person by the Court, parties may appear remotely either

SUPERIOR COURT OF CALIFORNIA COUNTY OF SACRAMENTO

25CV016139: STEPHENSON vs SACRAMENTO COUNTY SHERIFFS DEPARTMENT, et al. 09/03/2026 Hearing on Motion for Leave to File First Amended Complaint in Department 16C

telephonically or by video conference via the Zoom video/audio conference platform with notice to the Court and all other parties in accordance with Code of Civil Procedure §367.75. Although remote participation is not required, the Court will presume all parties are appearing remotely for non-evidentiary civil hearings.

The Department 16C Zoom Link is https://saccourt-cagov.zoomgov.com/j/16030877014 and the Zoom Meeting ID is 160 3087 7014. To appear on Zoom telephonically, call (833) 568-8864 and enter the Zoom Meeting ID referenced above. NO COURTCALL APPEARANCES WILL BE ACCEPTED.

Parties requesting services of a court reporter will need to arrange for private court reporter services at their own expense, pursuant to Government code §68086 and California Rules of Court, Rule 2.956. Requirements for requesting a court reporter are listed on the Court Reporter Services webpage available on the Sacramento Superior Court website at https://saccourt.ca.gov/general-information/court-reporter-servicestranscripts. Parties may contact Court- Approved Official Reporters Pro Tempore by utilizing the list of Court Approved Official Reporters Pro Tempore available at https://saccourt.ca.gov/home/showpublisheddocument/227/639084034465370000.

A Stipulation and Appointment of Official Reporter Pro Tempore (CV/E-206) is required to be signed by each party, the private court reporter, and the Judge prior to the hearing, if not using a reporter from the Court’s Approved Official Reporter Pro Tempore list.

Once the form is signed it must be filed with the clerk. If a litigant has been granted a fee waiver and requests a court reporter, the party must submit a Request for Court Reporter by a Party with a Fee Waiver (CV/E-211) and it must be filed with the clerk at least 10 days prior to the hearing or at the time the proceeding is scheduled if less than 10 days away. Once approved, the clerk will forward the form to the Court Reporter’s Office and an official reporter will be provided.