Fuller v. Thompson

CourtDistrict Court, N.D. California
DecidedJanuary 5, 2023
Docket4:22-cv-03802
StatusUnknown

This text of Fuller v. Thompson (Fuller v. Thompson) 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
Fuller v. Thompson, (N.D. Cal. 2023).

Opinion

1 UNITED STATES DISTRICT COURT 2 NORTHERN DISTRICT OF CALIFORNIA 3 KENNETH ADRIAN FULLER, 4 Case No. 22-cv-03802-YGR (PR) Plaintiff, 5 ORDER OF DISMISSAL v. 6 KAREN THOMPSON, et al., 7 Defendants. 8

9 I. INTRODUCTION 10 Plaintiff, who was formerly in custody at the Sonoma County Main Jail,1 filed the instant 11 pro se civil rights action pursuant to 42 U.S.C. § 1983. He has paid the full filing fee. Dkt. 6. 12 Plaintiff seeks injunctive and declaratory relief as well as monetary and punitive damages. 13 Plaintiff also requests appointment of counsel. Dkt. 1 at 3.2 14 The Court now reviews plaintiff’s complaint pursuant to 28 U.S.C. §1915. For the reasons 15 set forth below, the Court DISMISSES the complaint. 16 II. DISCUSSION 17 A. Standard of Review 18 A federal court must conduct a preliminary screening in any case in which a prisoner seeks 19 redress from a governmental entity or officer or employee of a governmental entity. See 28 U.S.C. 20 § 1915A(a). In its review, the court must identify any cognizable claims and dismiss any claims 21 that are frivolous, malicious, fail to state a claim upon which relief may be granted or seek 22 monetary relief from a defendant who is immune from such relief. See id. § 1915A(b)(1), (2). 23 Pro se pleadings must, however, be liberally construed. See Balistreri v. Pacifica Police Dep’t, 24 901 F.2d 696, 699 (9th Cir. 1988). 25 1 The Court notes that plaintiff has since been released from jail because he filed a Notice 26 of Change of Address on November 17, 2022, in which he provides his new address in Petaluma, California. See Dkt. 11. 27 1 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential elements: 2 (1) that a right secured by the Constitution or laws of the United States was violated, and (2) that 3 the alleged violation was committed by a person acting under the color of state law. See West v. 4 Atkins, 487 U.S. 42, 48 (1988). 5 B. Plaintiff’s Claims 6 1. Background 7 At the time plaintiff filed this action on June 29, 2022, he was incarcerated at the Sonoma 8 County Main Jail. Dkt. 1 at 1. Plaintiff’s complaint is handwritten, and the Court had difficulty 9 deciphering his handwriting. From what the Court could decipher, this action does not involve 10 plaintiff’s challenge to the conditions of his confinement. Instead, his complaint for injunctive/ 11 declaratory relief and monetary damages asserts numerous claims about the criminal case against 12 him. 13 It seems that on May 28, 2019, plaintiff, who was in custody at the jail, had faced 14 unspecified misdemeanor charges in the Sonoma County Superior Court, but the judge denied 15 plaintiff’s request to represent himself. Id. at 5. Sometime in late 2019 or early 2020, plaintiff 16 “posted bond and bailed out [of jail].” Id. at 19. It was not until March 2022 (after many court 17 proceedings involving plaintiff’s mental competency and also, presumably, due to delays caused 18 by the pandemic) that the judge granted plaintiff’s request to represent himself. Id. at 23. 19 However, on June 6, 2022, plaintiff claims that the judge “suspended criminal proceedings to 20 obtain another psychiatric evaluation.” Id. at 26-27. Thus, plaintiff claims that he filed this action 21 against Sonoma County Judges Jamie Thistlethwaite, Mark Urioste, Brad DeMeo, Shelly Averill, 22 Karlene Navarro, and Robert LaForge for “intentionally, willfully, [and] maliciously abus[ing] 23 Penal Code 1368 to instruct this plaintiff from exercising his constitutional right to represent 24 himself pursuant to Far[]etta v. California.” Id. at 27-28 (brackets added). Plaintiff also names 25 the following as defendants: Sonoma County Public Defenders Karen Thompson, Scott Roberts, 26 Lynn Stark-Slater, and Christine Brady; and Sonoma County Psychologists Drs. Correa and Doty. 27 Id. at 2, 4. Plaintiff claims that these aforementioned defendants “willfully, intentionally and 1 under color of law . . . to deprive plaintiff of ‘adequate access to the courts’ in violation of the 2 First and 14th Amendments of the U.S. Constitution.” Id. at 2-3 (brackets added). 3 2. Analysis of Claims Relating to Criminal Case Against Plaintiff 4 a. Younger Abstention 5 Under principles of comity and federalism, a federal court should not interfere with 6 ongoing state criminal proceedings by granting injunctive or declaratory relief absent extra- 7 ordinary circumstances. See Younger v. Harris, 401 U.S. 37, 43-54 (1971). Requests for 8 declaratory relief that would interfere with ongoing state criminal proceedings are subject to the 9 same restrictions that govern requests for injunctive relief. See Samuels v. Mackell, 401 U.S. 66, 10 71–74 (1971); Perez v. Ledesma, 401 U.S. 82, 86 n. 2 (1971). 11 Younger requires that federal courts refrain from enjoining or otherwise interfering with 12 ongoing state criminal proceedings where three conditions are met: (1) state judicial proceedings 13 are ongoing; (2) the state proceedings implicate important state interests; and (3) the plaintiff has 14 the opportunity to raise his federal constitutional concerns in the ongoing proceedings. Middlesex 15 County Ethics Comm. v. Garden State Bar Assn., 457 U.S. 423, 432 (1982); Dubinka v. Judges of 16 Superior Court of State of Cal. For County of Los Angeles, 23 F.3d 218, 223 (9th Cir. 1994). 17 Here, all three prongs of the abstention test are met. First, the state criminal proceedings 18 seem still to be ongoing in the Sonoma County Superior Court. Second, the criminal prosecution 19 involves important state interests. See Kelly v. Robinson, 479 U.S. 36, 49 (1986) (“the States’ 20 interest in administering their criminal justice systems free from federal interference is one of the 21 most powerful of the considerations that should influence a court considering equitable types of 22 relief”) (citing Younger, 401 U.S. at 44-45). Third, plaintiff can present his claims in the state trial 23 and appellate courts.3 24 3 A fourth requirement has also been articulated by the Ninth Circuit: that “the federal 25 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 26 San Jose, 546 F.3d 1087, 1092 (9th Cir. 2008) (citing cases).

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Bluebook (online)
Fuller v. Thompson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fuller-v-thompson-cand-2023.