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California Civil Procedure, Keyed to Levine, 6th Ed.
Sokolow v. County of San Mateo
Citation:
213 Cal. App. 3d 231, 261 Cal. Rptr. 520 (1989)Facts
Sonya Sokolow began attempting to join the Mounted Patrol of San Mateo County in 1975, but was excluded based on the organization’s males-only membership policy. The Patrol maintained an extraordinarily close relationship with the County Sheriff’s Department, with members sworn in as “Deputy Sheriffs,” issued official badges and identification cards, provided county training and resources, and presented to the public as an arm of the sheriff’s department. Despite the Patrol being technically a private nonprofit organization, the Sheriff served as “Commander-in-Chief,” county employees attended Patrol functions on paid time, and the sheriff’s office provided extensive support including inmate labor, equipment, and emergency services. After a decade of unsuccessful attempts to gain admission and requests that the discriminatory policy be changed or county ties severed, Sokolow filed suit in 1984 alleging violations of equal protection under state and federal constitutions and 42 U.S.C. Section 1983. The trial court granted summary judgment finding the governmental relationship created sufficient state action to subject the Patrol to constitutional requirements, and that the males-only policy violated Sokolow’s rights. The court gave the Patrol a choice: admit women or sever all ties with the county. The Patrol chose severance.
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