Al-Farouk v. Nelson

CourtDistrict Court, D. Nevada
DecidedOctober 13, 2023
Docket2:23-cv-01372
StatusUnknown

This text of Al-Farouk v. Nelson (Al-Farouk v. Nelson) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Al-Farouk v. Nelson, (D. Nev. 2023).

Opinion

2 UNITED STATES DISTRICT COURT 3 4 DISTRICT OF NEVADA *** 5 Yasmeen Al-Farouk, 6 Case No. 2:23-cv-01372-CDS-VCF

7 Plaintiff, ORDER vs. 8 Kristine Nelson, et al., 9 Defendants. 10

11 Plaintiff filed an application to proceed in forma pauperis (IFP), an amended complaint, and a 12 motion to file electronically. ECF Nos. 1, 4, and 5. I grant plaintiff’s IFP application and her motion to 13 file electronically. ECF Nos. 3 and 4. I dismiss her amended complaint without prejudice. ECF No. 5. 14 I. Whether Plaintiff May Proceed In Forma Pauperis 15 Under 28 U.S.C. § 1915(a)(1), a plaintiff may bring a civil action “without prepayment of fees or 16 security thereof” if the plaintiff submits a financial affidavit that demonstrates the plaintiff “is unable to 17 pay such fees or give security therefor.” Plaintiff states that she receives $1188 per month in Social 18 Security benefits and has $10 in her account. ECF No. 3. She states that she pays $750 per month in rent 19 20 with utilities and $25 per month for her phone. Id. I grant plaintiff’s IFP application. 21 II. Whether Plaintiff’s Complaint States a Plausible Claim 22 a. Legal Standard 23 Since I grant plaintiff’s IFP application, I review plaintiff’s complaint to determine whether the 24 complaint is frivolous, malicious, or fails to state a plausible claim. 28 U.S.C. § 1915(e)(2)(B). Federal 25 Rule of Civil Procedure 8(a)(2) provides that a complaint must contain “a short and plain statement of the claim showing that the [plaintiff] is entitled to relief.” Rule 8 ensures that each defendant has "fair 1 notice of what the plaintiff's claim is and the grounds upon which it rests." Dura Pharms., Inc. v. 2 Broudo, 544 U.S. 336, 346, 125 S. Ct. 1627, 161 L. Ed. 2d 577 (2005). The Supreme Court’s decision in 3 4 Ashcroft v. Iqbal states that to satisfy Rule 8’s requirements, a complaint’s allegations must cross “the 5 line from conceivable to plausible.” 556 U.S. 662, 680 (2009) (quoting Bell Atlantic Corp. v. Twombly, 6 550 U.S. 544, 547, (2007)). Rule 12(b)(6) of the Federal Rules of Civil Procedure provides for 7 dismissal of a complaint for failure to state a claim upon which relief can be granted. A complaint 8 should be dismissed under Rule 12(b)(6), “if it appears beyond a doubt that the plaintiff can prove no set 9 of facts in support of her claims that would entitle him to relief.” Buckey v. Los Angeles, 968 F.2d 791, 10 794 (9th Cir. 1992). 11 “[A] pro se complaint, however inartfully pleaded, must be held to less stringent standards than 12 formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (quoting Estelle v. 13 Gamble, 429 U.S. 97, 106 (1976)). If the Court dismisses a complaint under § 1915(e), the plaintiff 14 should be given leave to amend the complaint with directions as to curing its deficiencies, unless it is 15 clear from the face of the complaint that the deficiencies could not be cured by amendment. Cato v. 16 17 United States, 70 F.3d 1103, 1106 (9th Cir. 1995). 18 Section 1983 "'is not itself a source of substantive rights,' but merely provides 'a method for 19 vindicating federal rights elsewhere conferred.'" Graham v. Connor, 490 U.S. 386, 393-94, 109 S. Ct. 20 1865, 104 L. Ed. 2d 443 (1989) (quoting Baker v. McCollan, 443 U.S. 137, 144 n. 3, 99 S. Ct. 2689, 61 21 L. Ed. 2d 433 (1979)). To obtain relief pursuant to section 1983, a plaintiff must establish a "(1) a 22 violation of rights protected by the Constitution or created by federal statute, (2) proximately caused (3) 23 by conduct of a 'person' (4) acting under color of state law." Crumpton v. Gates, 947 F.2d 1418, 1420 24 (9th Cir. 1991). 25 2 b. Complaint 1 Plaintiff filed this action pursuant to 42 U.S.C. § 1983 alleging that the Department of 2 Employment, Training & Rehabilitation unlawfully denied her pandemic unemployment benefits. ECF 3 4 No. 5. Plaintiff alleges that she applied for Pandemic Unemployment Assistance, presumably pursuant 5 to the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) enacted by Congress on 6 March 27, 2020. Pub. L. No. 116-136, 134 Stat. 281 (2020). Plaintiff alleges that it took eight months to 7 receive a denial, and the denial lacked an explanation. Id. She alleges that she unsuccessfully appealed 8 to the Board of Review. Id. She also filed an unsuccessful writ of mandamus in state court. Id. 9 Plaintiff's allegations implicate her right to procedural due process under the Fourteenth 10 Amendment. To state a procedural due process claim, plaintiff must allege facts showing "(1) a 11 deprivation of a constitutionally protected liberty or property interest, and (2) a denial of adequate 12 procedural protections." Brewster v. Bd. of Educ. of Lynwood Unified Sch. Dist., 149 F.3d 971, 982 (9th 13 Cir. 1998). Plaintiff's complaint fails to establish these elements. 14 Plaintiff's complaint does not allege a protected property interest in unemployment assistance. 15 "To have a property interest in a benefit, a person clearly must have more than an abstract need or desire 16 17 for it. He must have more than a unilateral expectation of it. He must, instead, have a legitimate claim of 18 entitlement to it." Bd. of Regents v. Roth, 408 U.S. 564, 577, 92 S. Ct. 2701, 33 L. Ed. 2d 548 (1972). 19 Plaintiff does not allege facts plausibly suggesting that she qualified for and was entitled to receive 20 Pandemic Unemployment Assistance. Plaintiff alleges only that she was self-employed, but then became 21 unemployed in May 2020 because of the pandemic. Plaintiff alleges that she completed claims for 22 Pandemic Unemployment Assistance and received a denial eight months later. Plaintiff must allege facts 23 showing that he qualified for unemployment benefits to assert a protected property interest per Rule 8. 24 Plaintiff also fails to allege facts suggesting that the defendants failed to provide adequate 25 3 procedural protections, including notice of its decision and an opportunity for plaintiff to be heard. 1 Ludwig v. Astrue, 681 F.3d 1047, 1053 (9th Cir. 2012) ("Notice and [a meaningful] opportunity to be 2 heard are the hallmarks of procedural due process."). Plaintiff admits that she received notice of DETR’s 3 4 decision and filed an administrative appeal. She also filed a writ of mandamus in state court. Plaintiff 5 alleges that the appeals process was unfair, but nonetheless she maintains that she was able to pursue the 6 appeals process.

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Related

Board of Regents of State Colleges v. Roth
408 U.S. 564 (Supreme Court, 1972)
Estelle v. Gamble
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Baker v. McCollan
443 U.S. 137 (Supreme Court, 1979)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Carnegie-Mellon University v. Cohill
484 U.S. 343 (Supreme Court, 1988)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Dura Pharmaceuticals, Inc. v. Broudo
544 U.S. 336 (Supreme Court, 2005)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Evelyn Dejesus v. Banco Popular De Puerto Rico
951 F.2d 3 (First Circuit, 1991)
William Ludwig v. Michael Astrue
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Al-Farouk v. Nelson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/al-farouk-v-nelson-nvd-2023.