Felix v. County of Santa Clara

District Court, N.D. California·Decided October 3, 2024·No. 5:24-cv-00660·Unknown

Opinion

1 2 3 4 5 6 7

11 Case No. 24-cv-00660 BLF 12 DANIEL JOS EPH FELIX, ORDER DISMISSING FIRST Plaintiff, AMENDED COMPLAINT WITH 13 LEAVE TO AMEND v. 14

15 COUNTY OF SANTA CLARA, et al.,

16 Defendants.

18 Plaintiff, a state prisoner, filed a civil rights complaint pursuant to 42 U.S.C. § 1983 19 against the County of Santa Clara. Dkt. No. 1. The Court dismissed the complaint with 20 leave to amend for Plaintiff to attempt to state sufficient facts to state a cognizable claim. 21 Dkt. No. 13. Plaintiff filed a first amended complaint (“FAC”). Dkt. No. 14. 22 24 I. Standard of Review 25 A federal court must conduct a preliminary screening in any case in which a 26 prisoner seeks redress from a governmental entity or officer or employee of a 27 governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any 1 cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim 2 upon which relief may be granted or seek monetary relief from a defendant who is immune 3 from such relief. See id. § 1915A(b)(1),(2). Pro se pleadings must, however, be liberally 4 construed. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 5 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 6 elements: (1) that a right secured by the Constitution or laws of the United States was 7 violated, and (2) that the alleged violation was committed by a person acting under the 8 color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). 9 II. Plaintiff’s Claims 10 In the original complaint, Plaintiff named “Unidentified Santa Clara County 11 Authorities” as Defendant in this action. Dkt. No. 1 at 2. The Court found the complaint 12 lacked sufficient factual allegations describing the acts or conduct of any specific state 13 actor to support a cognizable claim for relief. Dkt. No. 13 at 2. 14 In the FAC, Plaintiff claims he is “a kidnapped, falsely arrested, falsely imprisoned, 15 T.I.N. man” who is incarcerated at the Santa Clara County Elmwood Facility. Dkt. No. 14 16 at 4. He names forty-four defendants which include three attorneys from the District 17 Attorney’s office, four superior court judges, an “administrative” officer, a county clerk, 18 four “government” officers, an officer from the Sheriff’s Department, and thirty San Jose 19 police officers (some by name and some by badge number). Id. at 4-25. Plaintiff asserts 20 thirty-six causes of action based on his allegations. Id. at 34-51. 21 Plaintiff alleges that on January 23, 2018, he was “falsely accused of illegal hearsay 22 evidence” by the San Jose Police Department. Id. at 26. On January 24, 2018, officers 23 came to his home to conduct an investigation, including an interview. Id. at 27-28. 24 Plaintiff includes allegations regarding evidence and witnesses during February 2018 and 25 September 2018. Id. at 28-30. Then on April 17, 2023, Plaintiff began to represent 26 himself in court as a “pro se defendant.” Id. at 30. He describes various court 1 proceedings, exchange of documents, and alleges denial of rights. Id. at 31-33. He seeks 2 declaratory judgment and damages. Id. at 53. 3 There are several issues with the amended complaint. First of all, Plaintiff’s 4 allegations indicate that his claims involve criminal charges and proceedings in Santa 5 Clara County. According to the County of Santa Clara’s Superior Court website, there is 6 at least one active felony complaint pending against Plaintiff (criminal case No. 7 C1801767).1 So it may be that Plaintiff is seeking to challenge those criminal proceedings 8 through this action. If so, there are several reasons why this matter may not proceed. 9 A. Younger Abstention 10 Under principles of comity and federalism, a federal court should not interfere with 11 ongoing state criminal proceedings by granting injunctive or declaratory relief absent 12 extraordinary circumstances. See Younger v. Harris, 401 U.S. 37, 43-46 (1971); Samuels 13 v. Mackell, 401 U.S. 66, 68-74 (1971). Younger abstention is required when: (1) state 14 proceedings, judicial in nature, are pending; (2) the state proceedings involve important 15 state interests; and (3) the state proceedings afford adequate opportunity to raise the 16 constitutional issue. See Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 17 U.S. 423, 432 (1982). All three elements must be present. Agriesti v. MGM Grand Hotels, 18 Inc., 53 F.3d 1000, 1001 (9th Cir. 1995) (abstention improper where arrest and issuance of 19 citation were executive acts not judicial in nature, and only potential for future state 20 judicial proceedings existed). A fourth requirement has also been articulated by the Ninth 21 Circuit: that “the federal court action would enjoin the state proceeding or have the 22 practical effect of doing so, i.e., would interfere with the state proceeding in a way that 23 Younger disapproves.” SJSVCCPAC v. City of San Jose, 546 F.3d 1087, 1092 (9th Cir. 24 2008) (citing cases). 25 It appears that Younger abstention may apply if the allegations in the amended 26 1 complaint are challenging the criminal action in Case No. C1801767 or any other pending 2 criminal action. Plaintiff shall be granted leave to file another amended complaint in 3 which he must either allege that criminal proceedings have concluded or show that 4 extraordinary circumstances warrant federal intervention to overcome Younger abstention. 5 B. Habeas Action 6 Even if Plaintiff has already been convicted and is challenging the constitutionality 7 of his conviction and sentence, a § 1983 action is not the appropriate avenue for such a 8 challenge. The constitutionality of state civil commitment proceedings may be challenged 9 in federal habeas corpus once state remedies have been exhausted. See Nelson v. 10 Sandritter, 351 F.2d 284, 285 (9th Cir. 1965). Furthermore, although a district court may 11 construe a habeas petition by a prisoner attacking the conditions of his confinement as a 12 civil rights action under 42 U.S.C. § 1983, see Wilwording v. Swenson, 404 U.S. 249, 251 13 (1971), the opposite is not true: A civil rights complaint seeking habeas relief should be 14 dismissed without prejudice to bringing it as a petition for writ of habeas corpus. See 15 Trimble v. City of Santa Rosa, 49 F.3d 583, 586 (9th Cir. 1995). Accordingly, if Plaintiff 16 is seeking to challenge his state conviction and sentence, this action should be dismissed 17 without prejudice to his refiling as a petition for habeas corpus pursuant to 28 U.S.C. §

Felix v. County of Santa Clara, (N.D. Cal. 2024).

Felix v. County of Santa Clara (Felix v. County of Santa Clara) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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