Felix v. Santa Clara County Office of the District Attorney

CourtDistrict Court, N.D. California
DecidedApril 12, 2024
Docket5:24-cv-00193
StatusUnknown

This text of Felix v. Santa Clara County Office of the District Attorney (Felix v. Santa Clara County Office of the District Attorney) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Felix v. Santa Clara County Office of the District Attorney, (N.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA

11 Case No. 24-cv-00193 BLF 12 DANIEL JOS EPH FELIX, ORDER OF DISMISSAL WITH Plaintiff, LEAVE TO AMEND; DENYING 13 MOTION FOR APPOINTMENT OF v. COUNSEL 14

15 SANTA CLARA CTY OFFICE OF THE DISTRICT ATTORNEY, 16

(Docket No. 10) 17 Defendant.

19 Plaintiff, a state prisoner, filed a civil rights complaint pursuant to 42 U.S.C. § 1983 20 against the Santa Clara County Office of the District Attorney. Dkt. No. 1. This matter 21 was reassigned to the undersigned. Dkt. No. 6. Plaintiff’s motion for leave to proceed in 22 forma pauperis will be addressed in a separate order. Dkt. No. 9. Plaintiff also moves for 23 appointment of counsel. Dkt. No. 10. 24

25 DISCUSSION 26 I. Standard of Review 27 1 prisoner seeks redress from a governmental entity or officer or employee of a 2 governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any 3 cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim 4 upon which relief may be granted or seek monetary relief from a defendant who is immune 5 from such relief. See id. § 1915A(b)(1),(2). Pro se pleadings must, however, be liberally 6 construed. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 7 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 8 elements: (1) that a right secured by the Constitution or laws of the United States was 9 violated, and (2) that the alleged violation was committed by a person acting under the 10 color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). 11 II. Plaintiff’s Claims 12 Plaintiff names only the Santa Clara County Office of the District Attorney as 13 Defendant in this action. Dkt. No. 1 at 1. He seeks declaratory and injunctive relief as 14 well as damages. Id. at 3. 15 The complaint fails to state any cognizable claim for relief against the named 16 Defendant. Plaintiff makes vague and confusing allegations about “further incompliance 17 of due process;” “pervasive unconstitutional violations in [Plaintiff’s] ability to effectively 18 redress the government for grievances;” “criminal act or gross negligence of duty against a 19 citizen or against the public generally” committed by an “official, officer, or clerk;” and “a 20 government infested with malfeasant officials, officers and clerks.” Id. at 2-3. The 21 complaint references 18 U.S.C. § 241, id. at 3, but this is a federal criminal statute for 22 which there is no private right of action, see Aldabe v. Aldabe, 616 F.2d 1089, 1092 (9th 23 Cir. 1980). Other than this reference, Plaintiff does not reference or identify any other 24 federal law, statute or constitutional provision, much less allege a violation thereof. Nor 25 does Plaintiff specifically reference the Santa Clara County District Attorney’s Office at 26 any point, much less allege a constitutional violation committed by the DA’s Office. 1 Lastly, in the prayer for relief, the complaint asks the court to dismiss state court 2 criminal case No. C1801767. According to the County of Santa Clara’s Superior Court 3 website, this case is a pending felony complaint against Plaintiff.1 So it may be that 4 Plaintiff is seeking to challenge pending criminal proceedings by suing the Santa Clara 5 County District Attorney’s Office for an unconstitutional prosecution. If so, there are 6 several problems why this matter may not proceed. 7 A. Younger Abstention 8 Under principles of comity and federalism, a federal court should not interfere with 9 ongoing state criminal proceedings by granting injunctive or declaratory relief absent 10 extraordinary circumstances. See Younger v. Harris, 401 U.S. 37, 43-46 (1971); Samuels 11 v. Mackell, 401 U.S. 66, 68-74 (1971). Younger abstention is required when: (1) state 12 proceedings, judicial in nature, are pending; (2) the state proceedings involve important 13 state interests; and (3) the state proceedings afford adequate opportunity to raise the 14 constitutional issue. See Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 15 U.S. 423, 432 (1982). All three elements must be present. Agriesti v. MGM Grand Hotels, 16 Inc., 53 F.3d 1000, 1001 (9th Cir. 1995) (abstention improper where arrest and issuance of 17 citation were executive acts not judicial in nature, and only potential for future state 18 judicial proceedings existed). A fourth requirement has also been articulated by the Ninth 19 Circuit: that “the federal court action would enjoin the state proceeding or have the 20 practical effect of doing so, i.e., would interfere with the state proceeding in a way that 21 Younger disapproves.” SJSVCCPAC v. City of San Jose, 546 F.3d 1087, 1092 (9th Cir. 22 2008) (citing cases). 23 There is insufficient information in the complaint for the Court to determine 24 whether Younger abstention applies because it is unclear what claims Plaintiff is 25 attempting to raise. Plaintiff shall be granted leave to amend to allege sufficient facts for 26 1 the Court to make this determination. He is advised that if there are ongoing criminal 2 proceedings against him, he must show that extraordinary circumstances warrant federal 3 intervention to overcome Younger abstention. 4 B. Habeas Action 5 On the other hand, if Plaintiff has already been convicted and is challenging the 6 constitutionality of his conviction and sentence, a § 1983 action is not the appropriate 7 avenue for such a challenge. The constitutionality of state civil commitment proceedings 8 may be challenged in federal habeas corpus once state remedies have been exhausted. See 9 Nelson v. Sandritter, 351 F.2d 284, 285 (9th Cir. 1965). Furthermore, although a district 10 court may construe a habeas petition by a prisoner attacking the conditions of his 11 confinement as a civil rights action under 42 U.S.C. § 1983, see Wilwording v. Swenson, 12 404 U.S. 249, 251 (1971), the opposite is not true: A civil rights complaint seeking habeas 13 relief should be dismissed without prejudice to bringing it as a petition for writ of habeas 14 corpus. See Trimble v. City of Santa Rosa, 49 F.3d 583, 586 (9th Cir. 1995). Accordingly, 15 if Plaintiff is seeking to challenge his state conviction and sentence, this action should be 16 dismissed without prejudice to his refiling as a petition for habeas corpus pursuant to 28 17 U.S.C. § 2254. He must make his status clear in an amended complaint. 18 C.

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Felix v. Santa Clara County Office of the District Attorney, Counsel Stack Legal Research, https://law.counselstack.com/opinion/felix-v-santa-clara-county-office-of-the-district-attorney-cand-2024.