## Facts

- David Williams was a qualified medical-marijuana patient under California law and participated in a seven-member patient collective that jointly cultivated marijuana at his residence for shared distribution among members.
- A Butte County deputy sheriff came to Williams’s home without a warrant and observed 41 marijuana plants.
- Williams presented physician recommendations or authorization documents for himself and the other collective members.
- The deputy, relying on a plant-limit guideline, threatened to arrest Williams unless he reduced the plants to 12.
- Williams destroyed 29 plants under the threat of arrest.
- Williams sued the County seeking money damages, alleging violations including unreasonable search and seizure and related state constitutional claims.

## Issues

1. Whether the California Constitution’s search-and-seizure provision (Cal. Const., art. I, § 13) implies a direct private cause of action for money damages against a county and its officers.
2. Whether the deputy’s warrantless conduct and coercive destruction order were unreasonable under California search-and-seizure standards (as a predicate context for remedies).

## Decision

- The Court of Appeal granted writ relief in part.
- The court held California Constitution article I, section 13 does not create an implied cause of action for money damages for unreasonable search and seizure.
- The court directed the superior court to vacate its order to the extent it allowed that state-constitutional damages claim to proceed and to sustain the County’s demurrer to that claim.
- The ruling did not necessarily bar Williams from pursuing other available nonconstitutional theories of relief.

## Legal Principles

- California courts will not infer a stand-alone damages remedy from the state Constitution’s search-and-seizure clause absent clear indicia that such a remedy was intended.
- Existing remedial schemes for unlawful searches (e.g., suppression in criminal cases, federal civil-rights actions for federal violations, and traditional statutory or tort remedies where applicable) weigh against implying a new state constitutional damages action.
- Recognizing an implied constitutional damages claim against public entities risks conflict with legislatively defined limits and procedures governing public-entity liability.
- When assessing a California law enforcement officer’s actions in this setting, the operative standards are those of California law the officer is charged to enforce, not federal marijuana prohibitions.

## Conclusion

The court limited remedies for alleged state constitutional search-and-seizure violations by holding that article I, section 13 does not itself authorize money damages, and it ordered the trial court to dismiss that specific constitutional damages claim while leaving other potential claims to proceed, if otherwise viable.


County of Butte v. Superior Court, 175 Cal. App. 4th 729 (Cal. Ct. App. 3d Dist. 2009)