Brooks v. Skagit County Public Health

CourtDistrict Court, W.D. Washington
DecidedJanuary 16, 2024
Docket2:23-cv-01708
StatusUnknown

This text of Brooks v. Skagit County Public Health (Brooks v. Skagit County Public Health) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brooks v. Skagit County Public Health, (W.D. Wash. 2024).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 FAWN BROOKS, CASE NO. 2:23-cv-01708-LK 11 Plaintiff, ORDER DISMISSING AMENDED 12 v. COMPLAINT 13 SKAGIT COUNTY PUBLIC HEALTH et al., 14 Defendants. 15 16 This matter comes before the Court sua sponte following Plaintiff Fawn Brooks’ filing of 17 an amended complaint. Dkt. No. 7. Ms. Brooks, who is proceeding pro se and in forma pauperis 18 (“IFP”), seeks money damages and an injunction arising from Defendants’ denial of her 19 application for emergency rental assistance. See id. at 4, 14. For the reasons discussed below, the 20 Court dismisses her complaint without prejudice pursuant to 28 U.S.C. § 1915(e)(2)(B). 21 I. BACKGROUND 22 On November 9, 2023, United States Magistrate Judge Brian A. Tsuchida granted Ms. 23 Brooks’ application to proceed IFP. Dkt No. 4. On November 15, 2023, after screening her 24 1 complaint pursuant to 28 U.S.C. § 1915(e), the Court declined to issue summons, dismissed Ms. 2 Brooks’ initial pleading without prejudice for failure to state a claim, and permitted her leave to 3 file an amended complaint within 30 days. Dkt. No. 6 at 3–4. The Court explained that although 4 Ms. Brooks may have a viable claim against one or more of the named Defendants, “the allegations

5 contained in the complaint [we]re too vague and conclusory to give rise to an inference of unlawful 6 conduct or to allow Defendants to effectively respond.” Id. at 3. In addition, the Court cautioned 7 Ms. Brooks that she may be legally barred from seeking relief from a state agency for constitutional 8 violations. Id. 9 On December 13, 2023, Ms. Brooks timely filed an amended complaint. Dkt. No. 7 at 1.1 10 She alleges that she is “a single person of low income” who, on or about August 17, 2022, applied 11 for a federally funded Emergency Rental Assistance (“ERA”) program2 through “the Skagit 12 Portal,” but was denied as a “result of not being of high . . . importance to help because of race and 13 internal interference.” Dkt. No. 7 at 4–5, 12; see also id. at 1 (“This is a claim . . . for the cause of 14 16 months of personal injury of [e]xtreme [e]motional distress by denying her a Federal statutory

15 program with discriminatory intent[.]”); id. at 6 (“Despite Brooks[’] repeat distressed emails, 16 attempts and even case number assignment, [f]rom August 2022–June 2023 Brooks was not able 17 to benefit from ERAP 2.0, Skagit ERPP,” and other housing assistance resources). This denial 18 “created very high stress levels” for her, exacerbated her mental health symptoms, and damaged 19 her relationship with her landlord which “will result in an eviction from her home of 7 years and 20 make it difficult to attain new housing.” Id. at 4; see also id. at 12. 21 1 Ms. Brooks’ amended complaint names the same five Defendants as her initial complaint, all of whom she alleges 22 were “working under the American Rescue Act of 2021”: (1) Skagit County Public Health; (2) Community Action of Skagit County; (3) Washington Department of Commerce; (4) Geocko, Inc., d.b.a. Livestories, Inc.; and (5) Allysen 23 Yamauchi, in her “official and individual capacity.” See id. at 2–4; Dkt. No. 5 at 2–3. 2 See U.S. Dep’t of Treasury, Emergency Rental Assistance Program, https://home.treasury.gov/policy- 24 issues/coronavirus/assistance-for-state-local-and-tribal-governments/emergency-rental-assistance-program (last visited Jan. 12, 2024). 1 Ms. Brooks takes issue with several aspects of how Defendants handled her application for 2 the emergency eviction prevention relief established by the federal government in response to the 3 COVID-19 pandemic. She questions Livestories’ authority—as “a tech/software company”—to 4 approve or deny such applications, and asserts that its decision to deny her application due to her

5 “landlord’s nonparticipation” does not comport with the requirements under the relevant statute, 6 15 U.S.C. § 9058a. Id. at 5. She also describes in more detail her communications with two staff 7 members of Defendant Community Action, a local housing assistance resource in Skagit County: 8 Eviction Prevention Specialist Noemi Ramirez and Defendant Yamauchi, a housing coordinator 9 at the organization. See id. (“Brooks emailed Ramirez about [her] current Mental Health crisis, job 10 loss, and the impact of denial,” and “sent a complaint to [Community Action] on 10/26/2022 and 11 exchanged emails with Yamauchi [on] Oct 26, 27, 28, Nov 1, 2, 3, and 7, without any resolve”). 12 Ms. Brooks alleges that Yamauchi told her that “the requests from [Livestories were] approved by 13 both Skagit County and Commerce” but that Community Action “would not accept [her] self- 14 attestation forms[.]” Id.; see also id. at 6 (Livestories was “authorized by Skagit and Commerce to

15 make final approval and flagged Brooks’ application without due process or investigating”). With 16 respect to the overall process, she avers that Livestories’ “standard practice only allows a 5-day 17 appeal and grievance window where 30–90 days is standard among these types of funds,” and that 18 Community Action and Livestories did not follow the statutory guidelines for “establish[ing] 19 policies and procedures to govern the implementation of their ERA programs[.]” Id. at 6; see also 20 id. (“On 01/17/23 Brooks emailed Yamauchi inquiring of other housing programs for help and was 21 unanswered.”). 22 Further, Ms. Brooks once again alleges that “Yamauchi and another director ha[ve] a 23 conflict of interest with a very adverse party to her personal rental situation.” Id.; see Dkt. No. 5

24 at 5. And she also re-alleges that “White Americans were excluded in [the] Skagit, [Community 1 Action], [Livestories], and Commerce [s]cope of work contracts.” Dkt. No. 7 at 5; see Dkt. No. 5 2 at 4. Based on these allegations, Ms. Brooks claims that 3 Defendants, by and through employees, and staff, breached the standard of care owed to [her] by: 1) failing to intervene where due process was proper[;] 2) failing 4 to recognize the deprivation’s extreme results of homelessness[;] 3) [f]ailing to include white Americans in scope of work[;] 4) allowing unauthorized criteria to 5 adversely block her approval[;] 5) [i]gnoring Brooks[’] complaints[; and] 6) violations for serious conflicts of interest. 6 Dkt. No. 7 at 6–7. As in her initial complaint, she invokes Title VI of the Civil Rights Act of 1964, 7 42 U.S.C. § 2000d et seq., the Fourteenth Amendment, 42 U.S.C. § 1983, and Section 4.96.020 of 8 the Revised Code of Washington. Id. at 7–11; see Dkt. No. 5 at 5–10. She asserts causes of action 9 for negligent infliction of emotional distress, abuse of power, and negligence, and also argues that 10 Community Action is “barred from a defense.” Dkt. No. 7 at 7–11. 11 II. DISCUSSION 12 A. Jurisdiction 13 This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1331 14 because Ms. Brooks alleges constitutional violations under 42 U.S.C. § 1983 and statutory 15 violations under the Civil Rights Act of 1964. See Dkt. No. 7 at 7–9. To the extent she alleges any 16 state law claims, the Court has supplemental jurisdiction over such claims under 28 U.S.C.

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Brooks v. Skagit County Public Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brooks-v-skagit-county-public-health-wawd-2024.