Felix v. County of Santa Clara

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

Opinion

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

COUNTY OF SANTA CLARA, et al.,

Defendants.

Plaintiff, a state prisoner, filed a civil rights complaint pursuant to 42 U.S.C. § 1983 against the County of Santa Clara. Dkt. No. 1. The Court dismissed the complaint with leave to amend for Plaintiff to attempt to state sufficient facts to state a cognizable claim. Dkt. No. 13. Plaintiff filed a first amended complaint (“FAC”). Dkt. No. 14. I. Standard of Review A federal court must conduct a preliminary screening in any case in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim upon which relief may be granted or seek monetary relief from a defendant who is immune from such relief. See id. § 1915A(b)(1),(2). Pro se pleadings must, however, be liberally construed. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential elements: (1) that a right secured by the Constitution or laws of the United States was violated, and (2) that the alleged violation was committed by a person acting under the color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). II. Plaintiff’s Claims In the original complaint, Plaintiff named “Unidentified Santa Clara County Authorities” as Defendant in this action. Dkt. No. 1 at 2. The Court found the complaint lacked sufficient factual allegations describing the acts or conduct of any specific state actor to support a cognizable claim for relief. Dkt. No. 13 at 2. In the FAC, Plaintiff claims he is “a kidnapped, falsely arrested, falsely imprisoned, T.I.N. man” who is incarcerated at the Santa Clara County Elmwood Facility. Dkt. No. 14 at 4. He names forty-four defendants which include three attorneys from the District Attorney’s office, four superior court judges, an “administrative” officer, a county clerk, four “government” officers, an officer from the Sheriff’s Department, and thirty San Jose police officers (some by name and some by badge number). Id. at 4-25. Plaintiff asserts thirty-six causes of action based on his allegations. Id. at 34-51. Plaintiff alleges that on January 23, 2018, he was “falsely accused of illegal hearsay evidence” by the San Jose Police Department. Id. at 26. On January 24, 2018, officers came to his home to conduct an investigation, including an interview. Id. at 27-28. Plaintiff includes allegations regarding evidence and witnesses during February 2018 and September 2018. Id. at 28-30. Then on April 17, 2023, Plaintiff began to represent himself in court as a “pro se defendant.” Id. at 30. He describes various court proceedings, exchange of documents, and alleges denial of rights. Id. at 31-33. He seeks declaratory judgment and damages. Id. at 53. There are several issues with the amended complaint. First of all, Plaintiff’s allegations indicate that his claims involve criminal charges and proceedings in Santa Clara County. According to the County of Santa Clara’s Superior Court website, there is at least one active felony complaint pending against Plaintiff (criminal case No. C1801767).1 So it may be that Plaintiff is seeking to challenge those criminal proceedings through this action. If so, there are several reasons why this matter may not proceed. A. Younger Abstention Under principles of comity and federalism, a federal court should not interfere with ongoing state criminal proceedings by granting injunctive or declaratory relief absent extraordinary circumstances. See Younger v. Harris, 401 U.S. 37, 43-46 (1971); Samuels v. Mackell, 401 U.S. 66, 68-74 (1971). Younger abstention is required when: (1) state proceedings, judicial in nature, are pending; (2) the state proceedings involve important state interests; and (3) the state proceedings afford adequate opportunity to raise the constitutional issue. See Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 432 (1982). All three elements must be present. Agriesti v. MGM Grand Hotels, Inc., 53 F.3d 1000, 1001 (9th Cir. 1995) (abstention improper where arrest and issuance of citation were executive acts not judicial in nature, and only potential for future state judicial proceedings existed). A fourth requirement has also been articulated by the Ninth Circuit: that “the federal court action would enjoin the state proceeding or have the practical effect of doing so, i.e., would interfere with the state proceeding in a way that Younger disapproves.” SJSVCCPAC v. City of San Jose, 546 F.3d 1087, 1092 (9th Cir. 2008) (citing cases). It appears that Younger abstention may apply if the allegations in the amended complaint are challenging the criminal action in Case No. C1801767 or any other pending criminal action. Plaintiff shall be granted leave to file another amended complaint in which he must either allege that criminal proceedings have concluded or show that extraordinary circumstances warrant federal intervention to overcome Younger abstention. B. Habeas Action Even if Plaintiff has already been convicted and is challenging the constitutionality of his conviction and sentence, a § 1983 action is not the appropriate avenue for such a challenge. The constitutionality of state civil commitment proceedings may be challenged in federal habeas corpus once state remedies have been exhausted. See Nelson v. Sandritter, 351 F.2d 284, 285 (9th Cir. 1965). Furthermore, although a district court may construe a habeas petition by a prisoner attacking the conditions of his confinement as a civil rights action under 42 U.S.C. § 1983, see Wilwording v. Swenson, 404 U.S. 249, 251 (1971), the opposite is not true: A civil rights complaint seeking habeas relief should be dismissed without prejudice to bringing it as a petition for writ of habeas corpus. See Trimble v. City of Santa Rosa, 49 F.3d 583, 586 (9th Cir. 1995). Accordingly, if Plaintiff is seeking to challenge his state conviction and sentence, this action should be dismissed without prejudice to his refiling as a petition for habeas corpus pursuant to 28 U.S.C. § 2254. He must clearly allege the status of criminal proceedings in an amended complaint. C. Heck Bar Furthermore, if Plaintiff is seeking damages for the wrongful conviction, he must prove that the conviction or sentence has been reversed on direc

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