Nathaniel Lee Smith v. Tuolumne County Jail, et al.

District Court, E.D. California·Decided March 2, 2026·No. 1:25-cv-00359·Unknown

Opinion

NATHANIEL LEE SMITH, Case No. 1:25-cv-00359-JLT-HBK (PC) Plaintiff, FINDINGS AND RECOMMENDATIONS TO DISMISS CASE1 v. (Doc. 20) TUOLUMNE COUNTY JAIL, et al., FOURTEEN-DAY OBJECTION PERIOD Defendants. Pending before the court for screening under 28 U.S.C. § 1915A is the pro se civil rights First Amended Complaint filed under 42 U.S.C. § 1983 by Nathaniel Smith—a pretrial detainee. (Doc. 20). For the reasons set forth below, the undersigned recommends the district court dismiss the First Amended Complaint for failure to state a claim without further leave to amend and direct the Clerk to close this case. A plaintiff who commences an action while in prison is subject to the Prison Litigation Reform Act (“PLRA”), which requires, inter alia, the court to screen a complaint that seeks relief against a governmental entity, its officers, or its employees before directing service upon any defendant. 28 U.S.C. § 1915A. This requires the court to identify any cognizable claims and 1 This matter was referred to the undersigned pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302 (E.D. Cal. 2025). dismiss the complaint, or any portion, if it is frivolous or malicious, if it fails to state a claim upon which relief may be granted, or if it seeks monetary relief from a defendant who is immune from such relief. See 28 U.S.C. §§ 1915A(b)(1), (2). At the screening stage, the court accepts the factual allegations in the complaint as true, construes the complaint liberally, and resolves all doubts in the plaintiff’s favor. Jenkins v. McKeithen, 395 U.S. 411, 421 (1969); Bernhardt v. L.A. County, 339 F.3d 920, 925 (9th Cir. 2003). A court does not have to accept as true conclusory allegations, unreasonable inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 618, 624 (9th Cir. 1981). Critical to evaluating a constitutional claim is whether it has an arguable legal and factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989). The Federal Rules of Civil Procedure require only that a complaint include “a short and plain statement of the claim showing the pleader is entitled to relief . . . .” Fed. R. Civ. P. 8(a)(2). Nonetheless, a claim must be facially plausible to survive screening. This requires sufficient factual detail to allow the court to reasonably infer that each named defendant is liable for the misconduct alleged. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Moss v. U.S. Secret Service, 572 F.3d 962, 969 (9th Cir. 2009). The sheer possibility that a defendant acted unlawfully is not sufficient, and mere consistency with liability falls short of satisfying the plausibility standard. Iqbal, 556 U.S. at 678; Moss, 572 F.3d at 969. Although detailed factual allegations are not required, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice,” Iqbal, 556 U.S. at 678 (citations omitted), and courts “are not required to indulge unwarranted inferences,” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation marks and citation omitted). To satisfy this plausibility standard, however, Rule 8 does not require a plaintiff to submit evidence of the claim at the pleading stage. Berk v. Choy, 607 U.S. __ at 3 (2026). If an otherwise deficient pleading can be remedied by alleging other facts, a pro se litigant is entitled to an opportunity to amend their complaint before dismissal of the action. See Lopez v. Smith, 203 F.3d 1122, 1127-29 (9th Cir. 2000) (en banc); Lucas v. Department of Corr., 66 F.3d 245, 248 (9th Cir. 1995). However, it is not the role of the court to advise a pro se litigant on how to cure the defects. Such advice “would undermine district judges’ role as impartial decisionmakers.” Pliler v. Ford, 542 U.S. 225, 231 (2004); see also Lopez, 203 F.3d at 1131 n.13. Furthermore, the court in its discretion may deny leave to amend due to “undue delay, bad faith or dilatory motive on the part of the movant, [or] repeated failure to cure deficiencies by amendments previously allowed . . . .” Carvalho v. Equifax Info. Srvs., LLC, 629 F.3d 876, 892 (9th Cir. 2010). Plaintiff, a pre-trial detainee proceeding pro se and in forma pauperis, initiated this action by filing a civil rights complaint under 42 U.S.C. § 1983 on March 26, 2025. (Doc. 1). On July 23, 2025,2 the court screened Plaintiff’s complaint and found that it failed to state any cognizable constitutional claim. (See Doc. 18). The court advised Plaintiff of the pleading deficiencies and applicable law and afforded Plaintiff the opportunity to file an amended complaint. (Id.). Plaintiff timely filed a First Amended Complaint on August 25, 2025. (Doc. 20, “FAC”). Plaintiff includes the names of various state court judges throughout his FAC, but specifically identifies the following individuals as Defendants: (1) Sergeant Matyshock, California Highway Patrol (“CHP”); (2) Officer Pullen, CHP; (3) Sergeant Rogers, Tuolumne County Sheriff’s Office (“TCSO”); (4) Cassandra Jenecke, Tuolumne County District Attorney; (5) Harry Elias, Judge (retired), Tuolumne County Superior Court; and (6) John and Jane Doe. (Doc. 20 at 3-4). 3 Plaintiff sues “all Defendants” in both their individual and official capacities. (Id. at 4). Plaintiff qualifies this statement by adding “Judges and DA only declarational [sic] ruling that they acted in violation of constitutional law.” 4 (Id.). Although not listed under 2 The Court awaited screening of the Complaint pending resolution of Plaintiff’s appeal to the Ninth Circuit Court of Appeals. (Docs. 12, 17). 3 The Court cites to the page numbers as reflected on the Court’s Management Electronic Case Filing system. 4 In an abundance of caution, the court construes these conflicting statements as Plaintiff seeking both monetary damages and declaratory relief against the state judges and district attorney. Defendants, consistent with Plaintiff suing ‘all” Defendants in both their individual and official capacities, Plaintiff identifies the following entities as Defendants on the caption of his FAC: (1) Tuolumne County Sheriff; (2) Tuolumne County DA; (3) Superior Court of Cali, Tuolumne; and (4) California Highway Patrol. (Id. at 1). The FAC asserts violations of Plaintiff’s First Amendment right to freedom of expression, Sixth Amendment right to a speedy trial, Eighth Amendment right to affordable bail, and Article VI, Clause 2 of the United States Constitution, the Supremacy Clause. (Id. at 4). Liberally construed, the FAC alleges that various county and state officials, including prosecutors, judges, and law enforcement officers, conspired to arrest and prosecute Plaintiff for comments he made on a podcast. In support, Plaintiff points to various court orders issued by different state court judges over a one year period that, inter alia, affected Plaintiff’s custody rights and child support payments and eventually resulted in his arrest and current pre-trial detention. (See generally, Doc. 20 at 5-9). The FAC contains cryptic

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Nathaniel Lee Smith v. Tuolumne County Jail, et al., (E.D. Cal. 2026).

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