Harris v. Ford

CourtDistrict Court, D. Nevada
DecidedMarch 26, 2025
Docket2:24-cv-01342
StatusUnknown

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

Bluebook
Harris v. Ford, (D. Nev. 2025).

Opinion

4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 * * * 7 RENE G. HARRIS, Case No. 2:24-cv-01342-RFB-EJY 8 Plaintiff, ORDER 9 v. 10 AARON FORD, 11 Defendant. 12

13 Before the Court for consideration is Plaintiff’s Objection (ECF No. 6) to the Order and 14 Report and Recommendation of the Honorable Elayna J. Youchah, United States Magistrate Judge, 15 entered on July 30, 2024 (ECF No. 5). For the following reasons, the Court denies the objection 16 and adopts the report and recommendation in full. 17 Pro se plaintiff Rene G. Harris initiated this action on July 22, 2024, by filing a Motion for 18 Constitutional/Declaratory Challenge. ECF No. 1. Mr. Harris challenges the constitutionality of a 19 Nevada statute inter alia outlining sentencing procedure for habitual criminals. Nev. Rev. Stat. 20 207.016. Specifically, Plaintiff alleges due process violations to the part of the statute that bars the 21 defendant from challenging the validity of a previous conviction at a hearing. Nev. Rev. Stat. 22 207.016(3). Mr. Harris also argues that NRS 207.016(3) is ambiguous and self-contradictory. On 23 July 30, 2024, Magistrate Judge Youchah issued an order denying Plaintiff’s motion, a 24 recommendation to follow Fed. R. Civ. P. 5.1, and a recommendation dismissing the case to the 25 extent Plaintiff wishes to file a habeas petition. ECF No. 5. Plaintiff timely objected to the order 26 denying his motion on August 12, 2024. ECF No. 6. The Court’s Order follows. 27 A magistrate judge may decide non-dispositive pretrial matters. Fed. R. Civ. P. 72(a); 28 28 1 U.S.C. § 636(b)(1)(A). The magistrate judge's order generally operates as a final determination. 2 LR IB 1-3. But if a party timely objects to the magistrate judge's order, a district court judge must 3 review the order and “set aside any part [...] that is clearly erroneous or is contrary to law.” Fed. 4 R. Civ. P. 72(a); 28 U.S.C. § 636(b)(1)(A); LR IB 3-1(a). “Clear error occurs when the reviewing 5 court on the entire record is left with the definite and firm conviction that a mistake has been 6 committed.” Smith v. Clark Cty. Sch. Dist., 727 F.3d 950, 950 (9th Cir. 2013) (internal quotation 7 marks and citations omitted). “An order is contrary to law when it fails to apply or misapplies 8 relevant statutes, case law, or rules of procedure.” Jadwin v. Cty. of Kern, 767 F. Supp. 2d 1069, 9 1110-11 (E.D. Cal. 2011) (internal quotation marks and citations omitted). The Court has 10 conducted a de novo review and does not find Judge Youchah’s Order clearly erroneous or 11 contrary to law. 12 In order to sue, a plaintiff must have Article III standing under the U.S. Constitution. See 13 Valley Forge Christian Coll. v. Ams. Utd. for Separation of Church & State, Inc., 454 U.S. 464, 14 471 (1982). To qualify as a party with standing to litigate, a plaintiff must (1) have suffered an 15 “injury in fact” that was (2) caused by the defendant’s challenged actions and would (3) be 16 “redressed by a favorable court decision.” Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 17 (1992) (internal citations omitted). This case turns on the first requirement: injury in fact. Mr. 18 Harris must show that he suffered “an invasion of a legally protected interest” that is “concrete 19 and particularized” and “actual or imminent, not conjectural or hypothetical.” Id. For an injury to 20 be “particularized,” it “must affect the plaintiff in a personal and individual way.” Sopeko, Inc. v. 21 Robins, 578 U.S. 330, 339 (2016). 22 Here, Mr. Harris fails to demonstrate an injury which affected him personally. In fact, he 23 clarifies that his claim “has nothing to do with” his particular case or any related prior conviction. 24 Instead, Plaintiff challenges the constitutionality of the Nevada statute generally. However, “[n]o 25 federal court . . . has jurisdiction to pronounce any statute, either of a State or of the United States, 26 void, because irreconcilable with the Constitution, except as it is called upon to adjudge the legal 27 rights of litigants in actual controversies.” Golden v. Zwickler, 394 U.S. 103, 110 (1969) (internal 28 citations omitted). Accordingly, to have standing in challenging the Nevada statute, Mr. Harris 1 must show that his legal rights were violated, i.e., there is an actual controversy rather than mere 2 abstraction. See United Public Workers of America v. Mitchell, 330 U.S. 75, 89 (1947) (“For 3 adjudication of constitutional issues, concrete legal issues, presented in actual cases, not 4 abstractions, are requisite. This is as true of declaratory judgments as any other field.”); see also 5 Diamond v. Charles, 476 U.S. 54, 62 (1986) (“Standing . . . to sue[] demands the litigant possess 6 a direct stake in the outcome.”) (internal citations omitted). Neither can Plaintiff satisfy the injury 7 requirement by alleging that an interest is shared generally with the public at large in the proper 8 application of the Constitution. See Lujan, 504 U.S. 573-76. Since Mr. Harris affirms that his 9 motion is irrelevant to his case, he has no legal interest in the outcome of the suit. The Court thus 10 finds that Mr. Harris lacks standing to litigate this action. In turn, the Court lacks jurisdiction to 11 address the merits of Plaintiff’s claim. 12 The Court lacks jurisdiction on other grounds as well. Plaintiff alleges that this Court has 13 jurisdiction under the Declaratory Judgment Act, 28 U.S.C § 2201. While the Declaratory 14 Judgment Act allows a federal court to “declare the rights and other legal relations of any interested 15 party,” it may only do so in cases “of actual controversy within its jurisdiction.” 28 U.S.C § 2201. 16 As discussed above, Plaintiff does not allege an actual controversy. Even if he did, the Declaratory 17 Judgment Act “does not by itself confer federal subject-matter jurisdiction,” for a plaintiff seeking 18 declaratory relief must “plead an independent basis for federal jurisdiction.” Nationwide Mut. Ins. 19 Co. v. Liberatore, 408 F.3d 1158, 1161 (9th Cir. 2005). For those reasons, the Court finds that 28 20 U.S.C § 2201

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United Public Workers of America v. Mitchell
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Flagg Bros., Inc. v. Brooks
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Diamond v. Charles
476 U.S. 54 (Supreme Court, 1986)
Will v. Michigan Department of State Police
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Lujan v. Defenders of Wildlife
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Jacqlyn Smith v. Clark County School District
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Harris v. Ford, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-ford-nvd-2025.