Lara

I.

FACTUAL AND PROCEDURAL BACKGROUND

On April 2, 2016, Jackson went to Misty’s Lounge (Misty’s), which is a nightclub located within the Doubletree by Hilton Ontario Airport (Hotel). After approximately an hour and a half, during which time Jackson consumed food and alcohol, a bartender refused to serve Jackson additional alcohol on the purported basis that Jackson was intoxicated. Jackson believed he was refused service based on his race, and he requested to speak to a supervisor. Mario Lara (Lara), the director of security for the Hotel, responded to Jackson’s complaint. Jackson and Lara initially discussed the matter inside Misty’s but then continued the discussion in the lobby of the Hotel. Lara confirmed the bartender’s decision and did not allow Jackson to re-enter Misty’s on the purported grounds that Jackson was intoxicated, and that Misty’s was closing at that time, which was the early morning of April 3, 2016. While Lara and Jackson were in the lobby, they came into physical contact with each other. Jackson believed that Lara initiated that contact, while Lara believed Jackson struck him. Lara then called the police and informed the responding officer that he wanted to…