Michela Brown v. County of El Dorado, et al.

District Court, E.D. California·Decided April 17, 2026·No. 2:26-cv-00186·Unknown

Opinion

1 2 3 4 5 6 7 10 11 MICHELA BROWN, Case No. 2:26-cv-00186-DC-CSK PS 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 COUNTY OF EL DORADO, et al., (ECF Nos. 1, 2) 15 Defendants. 16 17 Plaintiff Michela Brown is representing herself in this action and seeks leave to 18 proceed in forma pauperis (“IFP”) pursuant to 28 U.S.C. § 1915.1 (ECF No. 2.) For the 19 reasons that follow, the Court recommends that Plaintiff’s IFP application be denied, and 20 the Complaint be dismissed without leave to amend. 22 28 U.S.C. § 1915(a) provides that the court may authorize the commencement, 23 prosecution or defense of any suit without prepayment of fees or security “by a person 24 who submits an affidavit stating the person is “unable to pay such fees or give security 25 therefor.” This affidavit is to include, among other things, a statement of all assets the 26 person possesses. Id. The IFP statute does not itself define what constitutes insufficient 27 1 This matter proceeds before the undersigned pursuant to 28 U.S.C. § 636, Fed. R. 28 Civ. P. 72, and Local Rule 302(c). 1 assets. See Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015). In Escobedo, 2 the Ninth Circuit stated that an affidavit in support of an IFP application is sufficient 3 where it alleges that the affiant cannot pay court costs and still afford the necessities of 4 life. Id. “One need not be absolutely destitute to obtain benefits of the in forma pauperis 5 statute.” Id. Nonetheless, a party seeking IFP status must allege poverty “with some 6 particularity, definiteness and certainty.” Id. According to the United States Department 7 of Health and Human Services, the current poverty guideline for a household of one (not 8 residing in Alaska or Hawaii) is $15,060.00. See U.S. Dpt. Health & Human Service 9 (available at https://aspe.hhs.gov/poverty-guidelines). 10 Here, Plaintiff’s IFP request states that disability benefits are her only source of 11 income and she pays $3,995 a month in rent. See ECF No. 2. Plaintiff has made the 12 required showing under 28 U.S.C. § 1915(a). See id. However, the Court will 13 recommend Plaintiff’s IFP application be denied because the action is facially frivolous or 14 without merit because it fails to state a claim and lacks subject matter jurisdiction. “‘A 15 district court may deny leave to proceed in forma pauperis at the outset if it appears from 16 the face of the proposed complaint that the action is frivolous or without merit.’” Minetti v. 17 Port of Seattle, 152 F.3d 1113, 1115 (9th Cir. 1998) (quoting Tripati v. First Nat. Bank & 18 Tr., 821 F.2d 1368, 1370 (9th Cir. 1987)); see also McGee v. Dep’t of Child Support 19 Servs., 584 Fed. App’x 638 (9th Cir. 2014) (“the district court did not abuse its discretion 20 by denying McGee's request to proceed IFP because it appears from the face of the 21 amended complaint that McGee's action is frivolous or without merit”); Smart v. Heinze, 22 347 F.2d 114, 116 (9th Cir. 1965) (“It is the duty of the District Court to examine any 23 application for leave to proceed in forma pauperis to determine whether the proposed 24 proceeding has merit and if it appears that the proceeding is without merit, the court is 25 bound to deny a motion seeking leave to proceed in forma pauperis.”). Because it 26 appears from the face of the Complaint that this action is frivolous or is without merit as 27 discussed in more detail below, the Court recommends denying Plaintiff’s IFP motion. 28 / / / 2 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 3 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to 4 state a claim on which relief may be granted,” or “seeks monetary relief against a 5 defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 6 203 F.3d 1122, 1126-27 (2000) (en banc). A claim is legally frivolous when it lacks an 7 arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). In 8 reviewing a complaint under this standard, the court accepts as true the factual 9 allegations contained in the complaint, unless they are clearly baseless or fanciful, and 10 construes those allegations in the light most favorable to the plaintiff. See Neitzke, 490 11 U.S. at 327; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960 12 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011). 13 Pleadings by self-represented litigants are liberally construed. Hebbe v. Pliler, 627 14 F.3d 338, 342 & n.7 (9th Cir. 2010) (liberal construction appropriate even post–Iqbal). 15 However, the court need not accept as true conclusory allegations, unreasonable 16 inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 17 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does 18 not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); 19 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 20 To state a claim on which relief may be granted, the plaintiff must allege enough 21 facts “to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A 22 claim has facial plausibility when the plaintiff pleads factual content that allows the court 23 to draw the reasonable inference that the defendant is liable for the misconduct alleged.” 24 Iqbal, 556 U.S. at 678. A pro se litigant is entitled to notice of the deficiencies in the 25 complaint and an opportunity to amend unless the complaint’s deficiencies could not be 26 cured by amendment. See Lopez, 203 F.3d at 1130-31; Cahill v. Liberty Mut. Ins. Co., 80 27 F.3d 336, 339 (9th Cir. 1996). 28 / / / 2 Plaintiff brings this action against four named defendants: County of El Dorado, 3 Pippa Temple, Kassie Cardullo, and Jake Hermingaus. See Compl. (ECF No. 1). She 4 also lists South Lake Tahoe Police Department Detectives (“SLT Detectives”) as 5 defendants. Id. 6 Plaintiff alleges this action arises under 42 U.S.C. § 1983. Plaintiff alleges that 7 Defendant County of El Dorado “is responsible for policies and supervision of the District 8 Attorney’s Office.” Compl. at 1. Defendants Temple, Cardullo, and Hermingaus “were 9 employees of the DA’s Office.” Id. 10 Plaintiff alleges that, in a July 2025 investigation, Defendant SLT Detectives 11 “coerced, manipulated [and] pressured” her into making statements while she was 12 experiencing distress from mental health and substance abuse issues. Compl. at 1.

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Michela Brown v. County of El Dorado, et al., (E.D. Cal. 2026).

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