Edward Hernandez v. County of Los Angeles; City of Los Angeles; Judge Cohen-Laurie; and Superior Court of California County of Los Angeles

CourtDistrict Court, C.D. California
DecidedDecember 8, 2025
Docket2:25-cv-07271
StatusUnknown

This text of Edward Hernandez v. County of Los Angeles; City of Los Angeles; Judge Cohen-Laurie; and Superior Court of California County of Los Angeles (Edward Hernandez v. County of Los Angeles; City of Los Angeles; Judge Cohen-Laurie; and Superior Court of California County of Los Angeles) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edward Hernandez v. County of Los Angeles; City of Los Angeles; Judge Cohen-Laurie; and Superior Court of California County of Los Angeles, (C.D. Cal. 2025).

Opinion

1 JS-6 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 D EDWARD HERNANDEZ, Case No. 2:25-cv-07271-FLA (AGR) 3 Plaintiff, ORDER DISMISSING V. COMPLAINT WITHOUT LEAVE 14 TO AMEND 15 | COUNTY OF LOS ANGELES; CITY OF LOS ANGELES; JUDGE COHEN- 16 | LAURIE; and SUPERIOR COURT OF 17 | CALIFORNIA COUNTY OF LOS ANGELES, 18 Defendants. 19 20 21 Plaintiff, an inmate proceeding pro se and in forma pauperis, filed a civil 22 | rights complaint (the “Complaint”, Dkt. 1) against the County of Los Angeles, the 23 | City of Los Angeles, the Superior Court of California, County of Los Angeles 24 | (“Superior Court’), and Superior Court Judge Cohen-Laurie. 25 The court screens the Complaint to determine whether it fails to state a claim 26 | on which relief may be granted. 28 U.S.C. §§ 1915(e)(2)(B), 1915A. For the 27 | reasons set forth below, the court dismisses the Complaint without leave to amend. 28 | ///

1 LEGAL STANDARDS 2 “[A] complaint must contain sufficient factual matter, accepted as true, to 3 ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 4 662, 678 (2009) (citation omitted). “A claim has facial plausibility when the 5 plaintiff pleads factual content that allows the court to draw the reasonable 6 inference that the defendant is liable for the misconduct alleged. The plausibility 7 standard is not akin to a ‘probability requirement,’ but it asks for more than a sheer 8 possibility that a defendant has acted unlawfully. Where a complaint pleads facts 9 that are ‘merely consistent with’ a defendant’s liability, it ‘stops short of the line 10 between possibility and plausibility of entitlement to relief.’” Id. (citations and 11 internal quotation marks omitted). 12 The “tenet that a court must accept as true all of the allegations contained in a 13 complaint is inapplicable to legal conclusions. Threadbare recitals of the elements 14 of a cause of action, supported by mere conclusory statements, do not suffice.” Id.; 15 Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007). “In sum, … the non- 16 conclusory ‘factual content,’ and reasonable inferences from that content, must be 17 plausibly suggestive of a claim entitling the plaintiff to relief.” Moss v. U.S. Secret 18 Serv., 572 F.3d 962, 969 (9th Cir. 2009) (citation omitted). 19 The court generally limits its review to the operative pleading. See Lee v. 20 City of Los Angeles, 250 F.3d 668, 688 (9th Cir. 2001). However, materials that are 21 the subject of judicial notice and materials “submitted as part of the complaint” are 22 not “outside” the complaint and may be considered. Id.; Hal Roach Studios, Inc. v. 23 Richard Feiner & Co., 896 F.2d 1542, 1555 n. 19 (9th Cir. 1990). 24 A pro se complaint is “to be liberally construed.” Erickson v. Pardus, 551 25 U.S. 89, 94 (2007) (per curiam). Before dismissing a pro se civil rights complaint, 26 the plaintiff is given “notice of the deficiencies in his or her complaint” and 27 provided “an opportunity to amend the complaint to overcome deficiencies unless it 28 is clear [the deficiencies] cannot be cured by amendment.” Eldridge v. Block, 832 1 F.2d 1132, 1135–36 (9th Cir. 1987); see also Lopez v. Smith, 203 F.3d 1122, 1129 2 (9th Cir. 2000) (en banc). 3 ALLEGATIONS OF COMPLAINT 4 Plaintiff alleges he is currently a pretrial detainee in an unidentified state 5 court criminal action. Dkt. 1 (“Compl.”) at 7.1 Plaintiff further alleges that in an 6 earlier, different state court criminal case, styled People v. Hernandez, Case No. 7 3PB01415, in which he admitted to a felony violation of his post-release 8 community supervision pursuant to an agreement with the prosecutor, Superior 9 Court Judge Cohen-Laurie violated Plaintiff’s constitutional rights on June 21, 10 2023, by failing to calculate correctly both pre-conviction custody credits, under 11 Cal. Penal Code § 2900.5, and conduct credits, under Cal. Penal Code § 4019. 12 These errors allegedly resulted in Plaintiff’s over-detention.2 Compl. at 3, 5, 8, 9. 13 Plaintiff alleges that, on July 12, 2023, he filed a motion for resentencing in Case 14 No. 3PB01415. Plaintiff claims that, on July 31, 2023, Judge Cohen-Laurie granted 15 his motion for resentencing and issued a release order, which led to his release from 16 custody. Compl. at 11–14. Plaintiff contends he would have been released 44 days 17 earlier with the proper credits. Id. at 22. 18 The Complaint alleges four federal claims under 42 U.S.C. § 1983 19 (“§ 1983”) (Claims One, Four, Five, and Six) and two state law claims for violation 20 of mandatory duties and negligence (Claims Two and Three). Id. at 16–19, 22. 21 The Complaint seeks damages and punitive damages, jointly and severally against 22 Judge Cohen-Laurie and the Superior Court, as well as such other relief as the court 23 deems just and proper. Id. at 28–29. 24

25 1 Because the Complaint is not consecutively paginated, the court cites page numbers assigned by CM/ECF in the header of the Complaint. 26 2 According to Plaintiff, the sentence in Case No. 3PB01415 was supposed to run 27 concurrently with the sentence in a different criminal case, Case No. 3WC00708. 28 Compl. at 8. 1 DISCUSSION 2 A. Judicial Immunity 3 The Complaint names Superior Court Judge Cohen-Laurie as a defendant in 4 his official and individual capacities. However, “state judges are absolutely 5 immune from liability for their judicial acts.” Briscoe v. LaHue, 460 U.S. 325, 334 6 (1983); Stump v. Sparkman, 435 U.S. 349, 355–56 (1978). Judicial immunity 7 applies to claims under § 1983 and state law claims. Mireles v. Waco, 502 U.S. 9, 8 11 (1991) (per curiam) (§ 1983); Huffman v. Lindgren, 81 F.4th 1016, 1019, 1022 9 (9th Cir. 2023) (related state law claims). 10 Judicial immunity is not lost even if a complaint alleges that the judge’s 11 actions were erroneous, malicious, or in bad faith. Mireles, 502 U.S. at 11 12 (“judicial immunity is not overcome by allegations of bad faith or malice”); Stump, 13 435 U.S. at 356 (“judge will not be deprived of immunity because the action he 14 took was in error, done maliciously, or was in excess of his authority”). 15 Allegations of conspiracy do not overcome judicial immunity. Acres Bonusing, 16 Inc. v. Marston, 17 F.4th 901, 916 (9th Cir. 2021); Ashelman v. Pope, 793 F.2d 17 1072, 1077–78 (9th Cir. 1986). 18 Judicial immunity “is overcome in only two sets of circumstances. First, a 19 judge is not immune from liability for nonjudicial actions, i.e., actions not taken in 20 the judge’s judicial capacity. [Citations omitted.] Second, a judge is not immune 21 for actions, though judicial in nature, taken in the complete absence of all 22 jurisdiction.” Mireles, 502 U.S. at 11–12. 23 The Complaint does not allege any facts that overcome judicial immunity. 24 Examining the second circumstance first, the Complaint alleges Judge Cohen- 25 Laurie’s actions occurred in the context of a criminal case pending before him. 26 Thus, the Complaint does not and cannot allege actions in the complete absence of 27 all jurisdiction.

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Edward Hernandez v. County of Los Angeles; City of Los Angeles; Judge Cohen-Laurie; and Superior Court of California County of Los Angeles, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edward-hernandez-v-county-of-los-angeles-city-of-los-angeles-judge-cacd-2025.