(California Code of Civil Procedure §1085)

Petitioner:
Christina Urrutia Ureña

Respondents:
Town of Windsor, Windsor Police Department, and North Bay Animal Services (NBAS)

Subject of Petition:
Return of 28 dogs seized on December 9, 2025

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I. INTRODUCTION

Petitioner Christina Urrutia Ureña respectfully petitions this Court for a writ of mandamus compelling Respondents to perform their mandatory legal duties under California law by returning the 28 dogs unlawfully seized from her foster‑based rescue operation on December 9, 2025 in Windsor, California.

Respondents failed to comply with statutory requirements governing animal seizure, notice, documentation, due process, and post‑seizure procedures. As a result, Petitioner has been deprived of her property without lawful cause, without required notice, and without an opportunity to be heard, in violation of state law and constitutional protections.

A writ is necessary because Respondents have refused to return the animals, refused to provide required records, and continue to act outside the scope of their legal authority.

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II. JURISDICTION AND VENUE

This Court has jurisdiction under California Code of Civil Procedure §1085, which authorizes writs compelling government agencies and contracted entities to perform mandatory duties.

Venue is proper in this Court because the seizure occurred in Windsor, Sonoma County, and Respondents operate within this jurisdiction.

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III. PARTIES

Petitioner

Petitioner Christina Urrutia Ureña is the founder and director of a foster‑based animal rescue operating in Sonoma County. At all relevant times, she lawfully possessed and cared for the 28 dogs seized by Respondents.

Respondents

1. Town of Windsor – the municipal authority responsible for oversight of animal control operations.
2. Windsor Police Department – the agency that participated in or authorized the seizure.
3. North Bay Animal Services (NBAS) – a private contractor performing animal control and sheltering services on behalf of the Town of Windsor.

Each Respondent is legally obligated to comply with California seizure statutes, due process requirements, and mandatory post‑seizure procedures.

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IV. FACTUAL BACKGROUND

1. On December 9, 2025, Respondents seized 28 dogs from Petitioner’s rescue operation.
2. Respondents did not provide legally required written notice, including the reason for seizure, statutory authority, or instructions for reclaiming the animals.
3. Respondents did not provide an itemized list of animals taken, their condition, or any supporting documentation.
4. Petitioner was not given an opportunity to contest the seizure, request a hearing, or present evidence as required by California law.
5. Respondents have refused to return the animals, despite Petitioner’s repeated requests and despite the absence of any lawful order transferring ownership.
6. Respondents have withheld records, provided inconsistent explanations, and failed to comply with mandatory timelines and procedures.
7. The seizure and continued withholding of the animals constitute an unlawful deprivation of property and a violation of Petitioner’s due process rights.

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V. LEGAL BASIS FOR WRIT OF MANDAMUS

A writ of mandamus is appropriate when:

1. A public agency has a mandatory duty to act;
2. The petitioner has a clear and beneficial right to performance of that duty; and
3. No other adequate remedy exists.

Respondents violated mandatory duties under:

• California Food & Agricultural Code §§ 31108, 31752, 31753, 597.1
• California Penal Code §597.1
• California Constitution, Article I, §7 (due process)
• Contractual obligations between the Town of Windsor and NBAS

Respondents failed to:

• Provide required written notice
• Provide a hearing opportunity
• Provide documentation of the animals seized
• Follow statutory timelines
• Return the animals when no lawful basis existed to retain them

These failures make mandamus relief appropriate and necessary.

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VI. HARM SUFFERED

Petitioner has suffered:

• Loss of possession of 28 animals
• Damage to her rescue operations
• Reputational harm
• Emotional distress
• Interference with her ability to relocate her rescue and continue operations
• Ongoing deprivation of property without due process

No adequate legal remedy exists other than issuance of a writ.

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VII. REQUEST FOR RELIEF

Petitioner respectfully requests that this Court:

1. Issue a writ of mandamus compelling Respondents to immediately return the 28 dogs seized on December 9, 2025.
2. Order Respondents to produce all records, reports, photographs, and documentation related to the seizure.
3. Declare that Respondents violated mandatory statutory and constitutional duties.
4. Award costs and any other relief the Court deems just and proper.

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VIII. VERIFICATION

I, Christina Urrutia Ureña, declare under penalty of perjury under the laws of the State of California that the facts stated in this petition are true and correct to the best of my knowledge.

Executed on ____________, 2026

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SUPERIOR COURT OF CALIFORNIA

COUNTY OF SONOMA

CHRISTINA URRUTIA UREÑA,
Petitioner,

v.

TOWN OF WINDSOR,
WINDSOR POLICE DEPARTMENT, and
NORTH BAY ANIMAL SERVICES,
Respondents.

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PETITION FOR WRIT OF MANDAMUS
(California Code of Civil Procedure §1085)

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Petitioner:
Christina Urrutia Ureña

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PETITION FOR WRIT OF MANDAMUS

Petitioner Christina Urrutia Ureña alleges as follows:

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I. INTRODUCTION

1. Petitioner respectfully seeks a writ of mandamus compelling Respondents to perform their mandatory legal duties under California law by returning the 28 dogs unlawfully seized from her rescue operation on December 9, 2025 in Windsor, California.
2. Respondents failed to comply with statutory requirements governing animal seizure, notice, documentation, due process, and post‑seizure procedures. As a result, Petitioner has been deprived of her property without lawful cause, without required notice, and without an opportunity to be heard.
3. A writ is necessary because Respondents have refused to return the animals, refused to provide required records, and continue to act outside the scope of their legal authority.

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II. JURISDICTION AND VENUE

4. This Court has jurisdiction under Code of Civil Procedure §1085, which authorizes writs compelling government agencies and contracted entities to perform mandatory duties.
5. Venue is proper in Sonoma County because the seizure occurred in Windsor, and Respondents operate within this jurisdiction.

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III. PARTIES

A. Petitioner

6. Petitioner Christina Urrutia Ureña is the founder and director of a foster‑based animal rescue operating in Sonoma County. At all relevant times, she lawfully possessed and cared for the 28 dogs seized by Respondents.

B. Respondents

7. Town of Windsor is the municipal authority responsible for oversight of animal control operations.
8. Windsor Police Department participated in or authorized the seizure.
9. North Bay Animal Services (NBAS) is a private contractor performing animal control and sheltering services on behalf of the Town of Windsor.
10. Each Respondent is legally obligated to comply with California seizure statutes, due process requirements, and mandatory post‑seizure procedures.

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IV. FACTUAL BACKGROUND

11. On December 9, 2025, Respondents seized 28 dogs from Petitioner’s rescue operation.
12. Respondents did not provide legally required written notice, including the reason for seizure, statutory authority, or instructions for reclaiming the animals.
13. Respondents did not provide an itemized list of animals taken, their condition, or any supporting documentation.
14. Petitioner was not given an opportunity to contest the seizure, request a hearing, or present evidence as required by California law.
15. Respondents have refused to return the animals despite repeated requests and despite the absence of any lawful order transferring ownership.
16. Respondents have withheld records, provided inconsistent explanations, and failed to comply with mandatory timelines and procedures.
17. The seizure and continued withholding of the animals constitute an unlawful deprivation of property and a violation of Petitioner’s due process rights.

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V. LEGAL BASIS FOR WRIT OF MANDAMUS

18. A writ of mandamus is appropriate when:
    a. A public agency has a mandatory duty to act;
    b. The petitioner has a clear and beneficial right to performance of that duty; and
    c. No other adequate remedy exists.
19. Respondents violated mandatory duties under:

• California Food & Agricultural Code §§31108, 31752, 31753, 597.1
• California Penal Code §597.1
• California Constitution, Article I, §7
• Contractual obligations between the Town of Windsor and NBAS

20. Respondents failed to:

• Provide required written notice
• Provide a hearing opportunity
• Provide documentation of the animals seized
• Follow statutory timelines
• Return the animals when no lawful basis existed to retain them

21. These failures make mandamus relief appropriate and necessary.

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VI. HARM SUFFERED

22. Petitioner has suffered:

• Loss of possession of 28 animals
• Damage to her rescue operations
• Reputational harm
• Emotional distress
• Interference with relocation and ongoing operations
• Continued deprivation of property without due process

23. No adequate legal remedy exists other than issuance of a writ.

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VII. PRAYER FOR RELIEF

Petitioner respectfully requests that this Court:

1. Issue a writ of mandamus compelling Respondents to immediately return the 28 dogs seized on December 9, 2025.
2. Order Respondents to produce all records, reports, photographs, and documentation related to the seizure.
3. Declare that Respondents violated mandatory statutory and constitutional duties.
4. Award costs and any other relief the Court deems just and proper.

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VIII. VERIFICATION

I, Christina Urrutia Ureña, declare under penalty of perjury under the laws of the State of California that the facts stated in this petition are true and correct to the best of my knowledge.

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