Baldwin v. Nevada Attorney for Injured Workers Nevada

District Court, D. Nevada·Decided May 27, 2025·No. 2:24-cv-01208·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Linda Baldwin, Case No.: 2:24-cv-01208-JAD-MDC

4 Plaintiff Order Directing Filing of Third Amended 5 v. Complaint by June 27, 2025

6 Nevada Attorney for Injured Workers, et al., [ECF Nos. 12, 13, 14, 17] 7 Defendants

8 Pro se plaintiff Linda Baldwin sues the Nevada Attorney for Injured Workers, the State 9 of Nevada Department of Administration Hearing Division, and the State of Nevada Department 10 of Administration Hearing Appeals Division for events related to the denial of worker’s 11 compensation benefits. Because she is proceeding in forma pauperis, her pleading was 12 screened.1 The magistrate judge found that Baldwin’s amended complaint fails to establish a 13 prima facie Americans with Disabilities Act (ADA) claim because she does not identify what her 14 claimed “mobility impairment” is or how it substantially limits a major life activity.2 The 15 magistrate judge further observed that “plaintiff’s claim seems to arise from her disagreement 16 over denial of worker’s compensation benefits, and not a failure to accommodate some 17 established disability,” so she has “failed to establish a connection between her ‘disability’ and 18 the defendants’ actions.”3 He concluded that this action “is apparently an attempt to appeal an 19 unfavorable worker’s compensation claim determination, which is not necessarily an ADA 20 claim.”4 21 1 ECF No. 2. 22 2 ECF No. 11 at 6. 23 3 Id. at 7. 4 Id. 1 The magistrate judge then noted that some of Baldwin’s allegations appear to state a legal 2 malpractice claim against the Nevada Attorney for Injured Workers. But there is no such claim 3 under the ADA. Legal malpractice claims arise under state law, so the magistrate judge declined 4 to exercise supplemental jurisdiction over this one.5

5 Finally, the magistrate judge found that Baldwin’s claim against the Hearing Officer and 6 the Appeals Board is a de facto appeal of the decision by the Workers’ Compensation Board, 7 which cannot arise under the ADA. Even if Baldwin had pled the necessary elements of an ADA 8 claim against these officers, he explained, those claims would be barred by the doctrine of 9 judicial immunity.6 10 So the magistrate judge dismissed all of Baldwin’s claims with leave to file a second 11 amended complaint by February 28, 2025, if she could cure the defects in her first amended 12 complaint.7 Baldwin filed an objection to the magistrate judge’s order, a second amended 13 complaint, and an amended objection.8 14 A. Baldwin’s objections are overruled.

15 Baldwin’s first objection seems to suggest that her malpractice claim is brought under the 16 Federal Tort Claims Act.9 While this may have been her intention, it is certainly not clear by the 17 way she’s crafted the amended complaint. When deciding whether or not to dismiss a claim 18 during the screening process, the court is generally bound by the facts and allegations contained 19 20

21 5 Id. at 8. 6 Id. at 8–9. 22 7 Id. at 10. 23 8 ECF Nos. 12, 13, 14. 9 ECF No. 14 at 3. 1 within the four corners of the complaint.10 Because it was not apparent from the structure of and 2 allegations in the amended complaint that Baldwin intends to bring a malpractice claim under the 3 Federal Tort Claims Act, the magistrate judge did not err by failing to characterize it as such. 4 Baldwin’s next objection is “that she enforced a default Judgement [sic] against the

5 Defendants by amending the judgment with a sworn affidavit.”11 This court denied Baldwin’s 6 requests for a default judgment because no defendant was actually in default.12 Because this 7 case remains in the screening phase, Baldwin has not yet been authorized to serve any of her 8 pleadings on any defendant and thus no obligation for any defendant to respond has arisen. So 9 Baldwin is not entitled to the entry of default or a default judgment against any defendant at this 10 time. 11 Next, Baldwin provides three pages of details about how the denial of workers’ 12 compensation benefits makes the defendants “liable” for intentional infliction of emotional 13 distress.13 She writes that the defendants’ “tortious actions constitute an actionable tort, separate 14 and apart from” their statutory obligations under “the Texas Workers Compensation Act.”14

15 Again, if Baldwin intended to assert a claim for intentional infliction of emotional distress, this 16 17 18 19 20

21 10 Swartz v. KPMG LLP, 476 F.3d 756, 763 (9th Cir. 2007). 11 ECF No. 14 at 5. 22 12 See ECF No. 10. 23 13 Id. at 5–7. 14 Id at 7. was not made clear by her amended complaint, which contains only the following labeled causes 2|| of action: 3 ra STANDING 4 FIRST CAUSES OF ACTION INJUCTION 5 COUNT ONE: VIOLATION OF TITLE □□□ □□ ADA 6 7|| While there are many more headings within the complaint, these are the only theories that are 8]| labeled as causes of action or counts.’ If Baldwin’s intent is to object that the magistrate judge did not find that she had pled a viable claim for intentional infliction of emotional distress, that 10] objection is overruled because the complaint does not contain such a claim. 1] Finally, Baldwin objects that the defendants should have been served with and compelled answer her complaint before it was screened.'® But that’s not how this works. When a party 13]| seeks permission to pursue a civil case in forma pauperis, the court screens the complaint under 14]| 28 U.S.C. § 1915(e). The purpose of this early judicial-screening requirement is “to ensure that 15|| the targets of frivolous or malicious suits need not bear the expense of responding.”'” For this 16]| reason, the adversarial process—with the inclusion of the defendant—does not start until the court has determined that the plaintiff has stated a colorable claim. Because Baldwin has not yet 18 19 20 'S See ECF No. 7. ECF No. 14 at 8. 9 " Nordstrom vy. Ryan, 762 F.3d 903, 907 n.1 (9th Cir. 2014) (quoting Wheeler v. Wexford Health Sources, Inc., 689 F.3d 680, 681 (7th Cir. 2012)); See also Neitzke v. Williams, 490 U.S. 319, 3 327 (1989) (noting that a central function of this screening process is to “discourage the filing of, and waste of judicial and private resources upon, baseless lawsuits that paying litigants generally do not initiate because of the cost of bringing suit.”’).

1 pled a colorable claim, this case has not advanced beyond the screening process and no 2 defendant is yet obligated to answer. Baldwin’s objections are thus overruled. 3 B. Baldwin will be given leave to amend her complaint in light of the clarifications in 4 this order.

5 Baldwin’s second amended complaint was filed timely, but she did not have the benefit 6 of the clarifications above when drafting it. The only two causes of action she labels as such are 7 “STANDING. FIRST CAUSES OF ACTION INJUNCTION”18 and “COUNT TWO: 8 VIOLATION OF TITLE 11 OF ADA.”19 I also note that although the magistrate judge warned 9 Baldwin not to attach “documents contain[ing] personal identifiable information” like medical 10 records and social security numbers to her complaint,20 she again attached more than two 11 hundred pages of exhibits that contain personal identifiers. Finally, the filing of 263 pages as a 12 single chunk, without separating out and individually filing each exhibit, violates Local Rule IC 13 2-2(a)(3)(A).

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Baldwin v. Nevada Attorney for Injured Workers Nevada, (D. Nev. 2025).

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Related

Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Wheeler v. Wexford Health Sources, Inc.
689 F.3d 680 (Seventh Circuit, 2012)
Scott Nordstrom v. Charles Ryan
762 F.3d 903 (Ninth Circuit, 2014)