Sinaloa Lake Owners Ass'n v. City of Simi Valley

This appeal concerns a 42 U.S.C. § 1983 action against state officials for breaching a private dam and the consequent draining of a private lake. The dam was breached by officials of the California Division of Safety of Dams (“DSOD”) because they believed it was in a damaged condition and dangerous to the homeowners downstream. The DSOD is responsible for inspecting non-federally owned dams in California. At the close of the presentation of evidence by the plaintiffs and defendants, the district court entered judgment as a matter of law on the ground that the state officials were entitled to qualified immunity. The principal issue is whether, in light of the evidence presented at trial, the state officials were entitled to qualified immunity as a matter of law. We affirm the judgment of the district court.

*1098 I.

PROCEDURAL BACKGROUND

Sinaloa Lake Owners Association, Inc. (“SLOA”) owns a private dam and the lake behind the dam. The dam is an earthen structure, 800 feet long and 30 feet high, and is located upstream from the City of Simi Valley. In early 1983, after heavy rains raised the lake’s water level endangering the safety of the dam, the DSOD declared an emergency,…