Sami Ammari, who owns a cleaning service and adult entertainment business, sued the City of Los Angeles, building inspector Kim A. Beauchamp, and deputy city attorney Niklas Buckingham, alleging they conspired to use building code violations to stop his van advertising business in violation of his First and Fourteenth Amendment rights. Ammari claimed the conspiracy began in 2017 when inspectors issued violations for construction work at his Sun Valley property.
U.S. District Judge Maame Ewusi-Mensah Frimpong found no evidence linking the defendants to any 2017 conspiracy, noting that Beauchamp didn't start working for the Los Angeles Department of Building and Safety until 2019 and wasn't assigned to oversee Ammari's property until 2021. "Buckingham joined the Regulatory Prosecution Division in June 2019, and he only first became aware of Ammari and the Sun Valley Property in February 2020," Judge Frimpong wrote. The court found that "a reasonable jury could not 'infer from the circumstances that the alleged conspirators had a meeting of the minds [in 2017].'"
Ammari filed his original complaint in June 2024, amended it twice after a motion to dismiss, and failed to timely oppose defendants' initial summary judgment motion. The court granted Ammari additional time to file an opposition but issued an order to show cause for sanctions, which was later vacated after finding his counsel's conduct didn't rise to the level of willful misconduct.
The ruling eliminates both of Ammari's Section 1983 claims against the defendants. Since the court found no genuine dispute over whether a conspiracy existed, it didn't need to address the defendants' arguments about qualified immunity or prosecutorial immunity. The decision underscores the difficulty plaintiffs face in proving Section 1983 conspiracy claims without direct evidence of coordination between government officials.