Garcia v. Hays County, Texas

CourtDistrict Court, W.D. Texas
DecidedApril 13, 2020
Docket1:20-cv-00312
StatusUnknown

This text of Garcia v. Hays County, Texas (Garcia v. Hays County, Texas) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia v. Hays County, Texas, (W.D. Tex. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION CARLOS GARCIA #02126841 § § V. § A-20-CV-312-LY § HAYS COUNTY, TEXAS; CRIMINAL § DISTRICT ATTORNEY WES MAU; § and SHERIFF GARY CUTLER § REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE TO: THE HONORABLE LEE YEAKEL UNITED STATES DISTRICT JUDGE The Magistrate Judge submits this Report and Recommendation to the District Court pursuant to 28 U.S.C. §636(b) and Rule 1(f) of Appendix C of the Local Court Rules. Before the Court is Plaintiff’s complaint. Plaintiff, proceeding pro se, has been granted leave to proceed in forma pauperis. STATEMENT OF THE CASE At the time he filed his complaint pursuant to 42 U.S.C. § 1983, Plaintiff was confined in the the Bill Clements Unit of the Texas Department of Criminal Justice - Correctional Institutions Division. Plaintiff was convicted of one count of aggravated sexual assault of a child (count one) and five counts of indecency with a child (counts two through six). On April 3, 2017, the trial court sentenced Plaintiff to thirty-five years for the aggravated sexual assault, fifteen years for count two, ten years for count three, two years for count four, and five years for count five. For count six, the court sentenced Plaintiff to a ten-year suspended sentence and placed him on community supervision. The trial court ordered counts one, two, five, and six to run concurrently and counts three and four to run consecutively. The Thirteenth Court of Appeals affirmed Plaintiff’s conviction and sentences on March 28, 2019. Garcia v. State, No. 13-17-00218-CR, 2019 WL 1388532 (Tex. App. – Corpus Christi 2019, pet. ref’d). The Texas Court of Criminal Appeals refused Plaintiff’s petition for discretionary review on August 21, 2019. Garcia v. State, PD-0468-19 (Tex. Crim. App. 2019).

In this civil rights complaint Plaintiff alleges he was arrested on June 22, 2015, September 20, 2015, and May 11, 2016. Plaintiff asserts he paid his bail regarding his first and second arrest but was unable to pay regarding his third arrest. Plaintiff alleges bail was set without inquiring about his criminal history, employment history, family ties, flight risk or ability to pay. Plaintiff states he asked for an attorney before the start of his bail hearings but was denied counsel at all three hearings. Plaintiff sues Hays County, Texas; Wes Mau, Hays County Criminal District Attorney; and Gary Cutler, Hays County Sheriff. He asks the court to grant declaratory and

injunctive relief. Plaintiff does not specify what declaratory or injunctive relief he seeks. DISCUSSION AND ANALYSIS A. Standard Under 28 U.S.C. § 1915(e) According to 28 U.S.C. § 1915A(b)(1), this Court is required to screen any civil complaint in which a prisoner seeks relief against a government entity, officer, or employee and dismiss the complaint if the court determines it is frivolous, malicious, or fails to state a claim on which relief may be granted. See also 28 U.S.C. § 1915(e)(2)(B) (directing court to dismiss case filed in forma pauperis at any time if it is determined that action is (i) frivolous or malicious, or (ii) fails to state

claim on which relief may be granted). An action is frivolous where there is no arguable legal or factual basis for the claim. Neitzke v. Williams, 490 U.S. 319, 325 (1989). “A complaint lacks an arguable basis in law if it is based on 2 an indisputably meritless legal theory, such as if the complaint alleges a violation of a legal interest which clearly does not exist.” Harper v. Showers, 174 F.3d 716, 718 (5th Cir. 1999) (internal quotation and citation omitted). A complaint is factually frivolous when “the facts alleged are ‘fantastic or delusional

scenarios’ or the legal theory upon which a complaint relies is ‘indisputably meritless.’” Eason v. Thaler, 14 F.3d 8, n.5 (5th Cir. 1994) (quoting Neitzke, 490 U.S. at 327–28). In evaluating whether a complaint states a claim under sections 1915A(b)(1) and 1915(e)(2)(B), this Court applies the same standards governing dismissals pursuant to Rule 12(b)(6). See DeMoss v. Crain, 636 F.3d 145, 152 (5th Cir. 2011); see also FED. R. CIV. P. 12(b)(6). To avoid dismissal under Rule 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, ‘to state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v.

Twombly, 550 U.S. 544, 555–56, 570 (2007)); see FED. R. CIV. P. 12(b)(6). These factual allegations need not be detailed but “must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. A conclusory complaint—one that fails to state material facts or merely recites the elements of a cause of action—may be dismissed for failure to state a claim. See id. at 555–56. B. Statute of Limitations There is no federal statute of limitations for § 1983 actions. Piotrowski v. City of Houston,

51 F.3d 512, 514 n.5 (5th Cir. 1995); Henson-El v. Rogers, 923 F.2d 51, 52 (5th Cir. 1991), cert. denied, 501 U.S. 1235 (1991). Therefore, the Supreme Court has directed federal courts to borrow the forum state’s general personal injury limitations period. Owens v. Okure, 488 U.S. 235, 249-50 (1989). In Texas, the applicable limitations period is two years. Moore v. McDonald, 30 F.3d 616, 3 620 (5th Cir. 1994) (citing TEX. CIV. PRAC. & REM. CODE ANN. § 16.003(a) (Vernon 1986)). Nevertheless, federal law determines when a § 1983 cause of action accrues. Gartrell v. Gaylor, 981 F.2d 254, 257 (5th Cir . 1993). A cause of action under § 1983 accrues when the aggrieved party knows, or has reason to know of, the injury or damages which form the basis of the action.

Piotrowski, 51 F.3d at 516. Plaintiff complains of actions that occurred in 2015 and 2016. Further, he was convicted in 2017. Plaintiff did not execute his complaint until March 15, 2020, well after the expiration of the two-year limitations period. RECOMMENDATION It is therefore recommended that Plaintiff’s complaint be dismissed as frivolous pursuant to 28 U.S.C. § 1915(e).

It is further recommended that the Court include within its judgment a provision expressly and specifically warning Plaintiff that filing or pursuing any further frivolous lawsuits may result in (a) the imposition of court costs pursuant to Section 1915(f); (b) the imposition of significant monetary sanctions pursuant to Fed. R. Civ. P.

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Related

Eason v. Thaler
14 F.3d 8 (Fifth Circuit, 1994)
Moore v. McDonald
30 F.3d 616 (Fifth Circuit, 1994)
Piotrowski v. City of Houston
51 F.3d 512 (Fifth Circuit, 1995)
Harper v. Showers
174 F.3d 716 (Fifth Circuit, 1999)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Owens v. Okure
488 U.S. 235 (Supreme Court, 1989)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
DeMoss v. Crain
636 F.3d 145 (Fifth Circuit, 2011)
Larry D. Henson-El v. D.C. Rogers
923 F.2d 51 (Fifth Circuit, 1991)
William Hamilton Gartrell v. R.S. Gaylor
981 F.2d 254 (Fifth Circuit, 1993)

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Bluebook (online)
Garcia v. Hays County, Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-hays-county-texas-txwd-2020.