Lampkin v. Spangner

CourtDistrict Court, E.D. California
DecidedFebruary 10, 2025
Docket2:20-cv-01204
StatusUnknown

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

Bluebook
Lampkin v. Spangner, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 TRISHKA LAMPKIN, et al., Case No. 2:20-cv-1204-JAM-JDP 12 Plaintiffs, 13 v. FINDINGS AND RECOMMENDATIONS 14 SUPERIOR COURT OF CALIFORNIA, et al., 15 Defendants. 16 17 Plaintiffs Trishka Lampkin and Robert Cortez’s first amended complaint alleges claims 18 against defendants Superior Court of Sacramento County and Matthew Cortez for disclosing 19 plaintiff Lampkin’s address to Cortez, her former partner and abuser.1 ECF No. 60. The court 20 dismissed defendant Superior Court following a successful motion to dismiss. ECF No. 70. With 21 defendant Matthew remaining as the sole defendant, plaintiffs now move for default judgment 22 again him. ECF No. 77. I recommend that their motion be denied, the court decline to exercise 23 supplemental jurisdiction over plaintiffs’ harassment claim against Cortez, and that claim be 24 dismissed without prejudice to refiling in state court. 25 26 27 1 Considering that plaintiff Robert Cortez and defendant Matthew Cortez have the same 28 last name, the court will refer to those parties by their first names. 1 Background 2 Lampkin and Robert, a mother and son, brought this action against defendants for 3 disclosing Lampkin’s address to Matthew, Lampkin’s former partner and Robert’s biological 4 father. ECF No. 60 at 2. Specifically, plaintiffs allege that this disclosure occurred when a copy 5 of a court order concerning Robert was sent to Lampkin and Matthew, which included Lampkin’s 6 address. Id. at 3. Matthew is serving a life sentence for inflicting serious physical harm on 7 Lampkin and has indicated his intention to locate Lampkin upon his release. Id. at 2. 8 Plaintiffs’ initial complaint alleged claims against the County of Sacramento, M. Spagner 9 (a court clerk), and Matthew Cortez for violations of substantive due process, Monell liability 10 under 42 U.S.C. 1983, and declaratory relief. ECF No. 1. The court previously granted 11 Sacramento County’s motion for summary judgment, entered judgment in that defendant’s favor, 12 and dismissed plaintiff’s claims against Spagner. ECF Nos. 25 & 43. The court also ordered 13 plaintiffs to show cause why Matthew should not be dismissed based on their failure to prosecute. 14 Id. In response to the court’s order, plaintiffs moved for default judgment against Matthew. ECF 15 No. 49. The court denied the motion and dismissed the claims against Matthew with leave to 16 amend. ECF No. 59. 17 Plaintiffs filed a first amended complaint alleging claims against Matthew and the 18 Superior Court of Sacramento County for violations of substantive due process, declaratory relief, 19 and violation of California Code of Civil Procedure section 527.6 (civil harassment). ECF No. 20 60. The Superior Court filed a motion to dismiss, which the court granted. ECF No. 70. The 21 court then issued another order to show cause why Matthew should not be dismissed for failure to 22 prosecute. ECF No. 71. Plaintiffs now move for default judgment against Matthew on their 23 harassment claim, their only remaining claim.2 ECF No. 77. 24 2 A fair reading of the first amended complaint is that plaintiffs’ California civil 25 harassment claim is brought only against Matthew and their remaining claims are asserted only against the Superior Court. See ECF No. 60. To the extent that plaintiffs intended to allege their 26 § 1983 claim and related claim for declaratory relief against Matthew, those claims would be 27 subject to dismissal as the complaint provides no basis on which to conclude that Matthew—a private individual—was acting “under color of state law.” See Price v. Hawaii, 939 F.2d 702, 28 707-08 (9th Cir. 1991) (“[P]rivate parties are not generally acting under color of state law.”). 1 Legal Standard 2 Under Federal Rule of Civil Procedure 55, default may be entered against a party who 3 fails to plead or otherwise defend against an action. See Fed. R. Civ. P. 55(a). However, “[a] 4 defendant’s default does not automatically entitle the plaintiff to a court-ordered judgment.” 5 PepsiCo, Inc. v. Cal. Sec. Cans, 238 F. Supp. 2d 1172, 1174 (C.D. Cal. 2002) (citing Draper v. 6 Coombs, 792 F.2d 915, 924-25 (9th Cir. 1986)). In deciding a motion for default judgment, a 7 “district court has an affirmative duty to look into its jurisdiction over both the subject matter and 8 the parties.” In re Tuli, 172 F.3d 707, 712 (9th Cir. 1999). 9 In a civil action where a district court has original jurisdiction but the claims over which 10 the federal court has original jurisdiction are abandoned or dismissed, the court “may decline to 11 exercise supplemental jurisdiction” over the related state law claims. 28 U.S.C. § 1367(c). The 12 decision to retain or decline jurisdiction must be made in light of “the objectives of economy, 13 convenience and fairness to the parties, and comity.” Trustees of Constr. Indus. and Laborers 14 Health and Welfare Trust v. Desert Valley Landscape & Maintenance, Inc., 333 F.3d 923, 925, 15 64 F. App’x 60 (9th Cir. 2003). “[I]n the usual case in which all federal-law claims are 16 eliminated before trial, the balance of factors . . . will point toward declining to exercise 17 jurisdiction over the remaining state-law claims.” Carnegie-Mellon Univ. v. Cohill, 484 U.S. 18 343, 350 n.7 (1988); see Parra v. PacifiCare of Ariz. Inc., 715 F.3d 1146, 1156 (9th Cir. 2013) 19 (“[O]nce the district court, at an early stage of the litigation, dismissed the only claim over which 20 it had original jurisdiction, it did not abuse its discretion in also dismissing the remaining 21 claims.”). 22 Discussion 23 Plaintiffs seek default judgment against Matthew and an injunction prohibiting him from 24 contacting Lampkin pursuant to Cal. Code Civ. Proc. § 527.6. ECF No. 77 at 8-9. Before 25 assessing the merits of a default judgment, a court must confirm that it has subject matter 26 jurisdiction over the case and personal jurisdiction over the parties. See In re Tuli, 172 F.3d at 27 Accordingly, the court considers the first amended complaint to allege a singular claim under 28 California Civil Procedure Code section 527.6 against Matthew. 1 712. 2 Federal courts are courts of limited jurisdiction, and a “federal court is presumed to lack 3 jurisdiction in a particular case unless the contrary affirmatively appears.” Stock W., Inc. v. 4 Confederated Tribes, 873 F.2d 1221, 1225 (9th Cir. 1989) (citations omitted). A federal court 5 may have original jurisdiction over a matter based on federal question jurisdiction or diversity 6 jurisdiction and may extend supplemental jurisdiction over related state law claims. See 28 7 U.S.C. §§ 1332, 1367. Here, the sole remaining claim in this matter is based on state law, and 8 diversity jurisdiction is not satisfied, because all parties are alleged to reside in California. ECF 9 No.

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Lampkin v. Spangner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lampkin-v-spangner-caed-2025.