Oelker v. State of Idaho

CourtDistrict Court, D. Idaho
DecidedDecember 20, 2024
Docket1:24-cv-00410
StatusUnknown

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

Bluebook
Oelker v. State of Idaho, (D. Idaho 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

JEROMY OELKER, Case No. 1:24-cv-00410-AKB

Plaintiff, INITIAL REVIEW ORDER BY SCREENING JUDGE v.

STATE OF IDAHO, et al.,

Defendants.

I. INTRODUCTION Plaintiff Jeromy Oelker filed an Application to Proceed in Forma Pauperis, a Complaint, and two Petitions for Writ of Habeas Corpus in the United States District Court for the District of Nevada, which have been transferred to this Court pursuant to 28 U.S.C. § 1406(a). (Dkts. 1, 5). The Clerk of this Court conditionally filed Oelker’s Complaint for a Civil Case (Dkt. 1-1) and Petitions for Writ of Habeas Corpus (Dkts. 1-2, 1-3, 7). (Dkt. 7). Pursuant to 28 U.S.C. § 1915, the Court reviews Oelker’s request to determine whether he is entitled to proceed in forma pauperis, which permits civil litigants to proceed without prepayment of the filing fee or to pay the filing fee over time. Rice v. City of Boise City, No. 1:13-CV-00441-CWD, 2013 WL 6385657, at *1 (D. Idaho Dec. 6, 2013). The Court also undertakes an initial review of Oelker’s Complaint to ensure it meets the minimum required standards. See 28 U.S.C. § 1915(e)(2)(B). For the reasons explained below, the Court denies Oelker’s In Forma Pauperis Application and dismisses his Complaint for failure to state a claim for relief. Specifically, the Court dismisses with prejudice Oelker’s various claims against the State of Idaho, Public Defender Brennan Wright, and Chief Judge David Nye for the reasons set forth below. II. APPLICATION TO PROCEED IN FORMA PAUPERIS “[A]ny court of the United States may authorize the commencement, prosecution or

defense of any suit, action or proceeding, civil or criminal . . . without prepayment of fees or security therefor.” 28 U.S.C. § 1915(a)(1). To qualify for In Forma Pauperis status, a plaintiff must submit an affidavit that includes a statement of all assets he possesses and that indicates he is unable to pay the fee required. The affidavit is sufficient if it states the plaintiff, because of his poverty, cannot “pay or give security for the costs” and still be able to provide for himself and dependents the “necessities of life.” Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 (1948). The affidavit must “state the facts as to affiant’s poverty with some particularity, definiteness and certainty.” United States v. McQuade, 647 F.2d 938, 940 (9th Cir. 1981) (internal quotation marks omitted). The Court may deny an in forma pauperis application—and may even dismiss a case—if

the plaintiff’s complaint (1) is frivolous or malicious, (2) fails to state a claim upon which relief may be granted, or (3) seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see also O’Loughlin v. Doe, 920 F.2d 614, 616 (9th Cir. 1990) (stating that a court may “deny leave to proceed in forma pauperis at the outset if it appears from the face of the proposed complaint that the action is . . . without merit.” (internal quotation marks and alteration omitted). The Court has reviewed Oelker’s in forma pauperis application. Oelker’s attached affidavit specifies lack of income, cash on hand, expenses, and debts. (Dkt. 1). The affidavit, however, omits the value of his home and vehicle, asserting that each is unavailable to him due to ongoing criminal proceedings. (Id. at p. 2). He has $40 of cash on hand. (Id.). Because his monthly income is $0 and monthly expenses are $150, Oelker’s monthly expenses exceed his income by about $150 each month. (Id.). Notwithstanding Oelker’s poverty, as outlined below, the Court finds he has failed to state

a claim upon which relief can be granted. Accordingly, the application is denied. See 28 U.S.C. § 1915(e)(2)(B)(ii). III. SUFFICIENCY OF COMPLAINT A. All Claims Against Each Individual Defendant Fail Oelker’s claims against the named defendants each fail to state a claim upon which relief can be granted. Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To state a plausible civil rights claim, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991).

Oelker also asserts claims under Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 (1971). (Dkt. 1-1 at pp. 3-4). In Bivens, the United States Supreme Court recognized a cause of action for monetary damages against federal officials in their individual capacities for a violation of constitutional rights. A Bivens action is the federal equivalent to an action brought under § 1983, and a plaintiff asserting a Bivens claim must show that the defendant was acting under color of federal law. Cox v. Hellerstein, 685 F.2d 1098, 1099 (9th Cir. 1982). The Complaint does not state a plausible § 1983 or Bivens claim. 1. The State of Idaho The first named Defendant is the State of Idaho. However, under the principle of sovereign immunity enshrined in the Eleventh Amendment to the U.S. Constitution, states and state entities are immune from suit in federal court. See Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S.

89, 100 (1984); Hans v. Louisiana, 134 U.S. 1, 16-18 (1890). If Plaintiff intends to pursue his claims against the State of Idaho, he must do so in state court. 2. Public Defender Brennan Wright Oelker asserts that the public defender in his state criminal action, Brennan Wright, violated Plaintiff’s “1st, 4th, 5th, 6th, 8th, 9th, and 14th” amendment rights by “refus[ing] to defend [his] right to fairness and adversary process by [o]mission” and “furthering the conspiracy to keep [him] [u]nlawfully restrained.” (Dkt. 1-1 at p. 3) (cleaned up). Oelker further asserts that Wright’s failure to object to the Lewis County Court’s imposition of bail amounted to ineffective assistance of counsel. (Dkt. 1 at p. 6; Dkt. 1-4 at pp. 15-16). Oelker alleges Wright wrongfully failed to object to perceived violations by the county, resulting in the current warrant for Oelker’s

arrest and contributing to the claimed unlawful restraint of liberty. (Dkt. 1 at p. 5). The law is clear that a public defender does not act under color of state law when representing an indigent defendant in criminal proceedings. Cox, 685 F.2d at 1099 (federal criminal context). Therefore, the Court lacks jurisdiction over Plaintiff’s claims. See id. In West v. Atkins, 487 U.S. 42 (1988), the United States Supreme Court explained: [In] Polk County v. Dodson, [

Related

Hans v. Louisiana
134 U.S. 1 (Supreme Court, 1890)
Adkins v. E. I. DuPont De Nemours & Co.
335 U.S. 331 (Supreme Court, 1948)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Pennhurst State School and Hospital v. Halderman
465 U.S. 89 (Supreme Court, 1984)
Forrester v. White
484 U.S. 219 (Supreme Court, 1988)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Douglas Gregory v. John J. Thompson
500 F.2d 59 (Ninth Circuit, 1974)
Edward G. Eldridge v. Sherman Block
832 F.2d 1132 (Ninth Circuit, 1987)

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Oelker v. State of Idaho, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oelker-v-state-of-idaho-idd-2024.