(PC) Gates v. Sergent

CourtDistrict Court, E.D. California
DecidedApril 26, 2024
Docket2:22-cv-01576
StatusUnknown

This text of (PC) Gates v. Sergent ((PC) Gates v. Sergent) 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
(PC) Gates v. Sergent, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 CHRISTIAN D. GATES, No. 2: 22-cv-1576 DAD CSK P 12 Plaintiff, 13 v. ORDER 14 S. SERGENT, et al., 15 Defendants. 16 17 I. Introduction 18 Plaintiff is a state prisoner, proceeding without counsel, with a civil rights action pursuant 19 to 42 U.S.C. § 1983. Pending before the court is defendants’ unopposed motion to stay this 20 action pending resolution of state criminal proceedings against plaintiff. (ECF No. 39.) 21 For the reasons stated herein, defendants’ motion to stay is granted. 22 II. Plaintiff’s Claims 23 This action proceeds on plaintiff’s complaint, filed September 8, 2022, as to plaintiff’s 24 Eighth Amendment excessive force claims against defendants Culum, Baliton, Gann, Sergent and 25 Reynolds. (ECF No. 1.) Plaintiff alleges that on September 5, 2020, plaintiff told Correctional 26 Officer Gallegos that plaintiff had safety concerns with his cellmate. (Id. at 5.) Defendants 27 Culum and Baliton then threw plaintiff into a wheelchair with the purpose of throwing plaintiff 28 back into his cell. (Id.) Both of plaintiff’s ankles were shackled to the wheelchair. (Id.) Upon 1 arriving at his cell, plaintiff refused to exit the wheelchair. (Id.) Defendants Culum and Baliton 2 then snatched plaintiff out of the wheelchair, dragged plaintiff to the cell and threw plaintiff into 3 the steel door frame, causing injuries to plaintiff’s right shoulder. (Id.) 4 After plaintiff fell to the ground, defendant Culum began kicking and stomping on 5 plaintiff’s legs. (Id.) Defendant Gann slammed the door on plaintiff’s right knee and defendant 6 Sergent stomped on plaintiff’s right ankle repeatedly. (Id.) Plaintiff alleges that defendant 7 Reynolds stood by watching the assault. (Id. at 6.) 8 As relief, plaintiff seeks money damages. (Id. at 8.) 9 III. Pending Criminal Proceedings Against Plaintiff 10 In the motion to stay, defendants state that plaintiff has criminal charges pending against 11 him in Amador County Superior Court for felony battery against defendant Sergent arising out of 12 the September 5, 2020, incident. (See ECF No. 39-1.) The criminal complaint against plaintiff 13 was filed on January 4, 2021. (Id. at 5.) 14 The charges against plaintiff are apparently based on the descriptions of the incident in the 15 staff narrative reports prepared by prison officials following the incident. (Id. at 26-32.) These 16 reports state that on September 5, 2020, defendants Culum and Balton escorted plaintiff to his cell 17 by wheelchair. (Id.) After plaintiff’s restraints were removed, plaintiff was escorted to his cell 18 door when he abruptly fell to the ground. (Id.) Defendant Sergent approached the cell and 19 plaintiff kicked her in the right knee. (Id.) The felony battery charges against plaintiff are 20 apparently based on the claim that plaintiff kicked defendant Sergent in the right knee. 21 Plaintiff’s criminal trial is currently expected to be set at a hearing on April 26, 2024. (Id. 22 at 38.) 23 IV. Motion to Stay 24 Defendants move to stay this action pursuant to Heck v. Humphrey, 512 U.S. 477 (1994), 25 Wallace v. Kato, 549 U.S. 384 (2007) and Younger v. Harris, 401 U.S. 37 (1971). (ECF No. 39 26 at 1.) 27 The district court “has broad discretion to stay proceedings as an incident to its power to 28 control its own docket.” Clinton v. Jones, 520 U.S. 681, 706 (1997) (citing Landis v. North 1 American Co., 299 U.S. 248, 254 (1936)). A stay is discretionary and the “party requesting a stay 2 bears the burden of showing that the circumstances justify an exercise of that discretion.” Nken 3 v. Holder, 556 U.S. 418, 433–34 (2009). “Generally, stays should not be indefinite in nature.” 4 Dependable Highway Exp., Inc. v. Navigators Ins. Co., 498 F.3d 1059, 1066–67 (9th Cir. 2007). 5 If a stay is especially long or its term is indefinite, a greater showing is required to justify it. 6 Yong v. I.N.S., 208 F.3d 1116, 1119 (9th Cir. 2000). The court should “balance the length of any 7 stay against the strength of the justification given for it.” Id. 8 “The Constitution does not ordinarily require a stay of civil proceedings pending the 9 outcome of criminal proceedings.” Keating v. Office of Thrift Supervision, 45 F.3d 322, 324 (9th 10 Cir. 1995). “’In the absence of substantial prejudice to the rights of the parties involved, 11 [simultaneous] parallel [civil and criminal] proceedings are unobjectionable under our 12 jurisprudence.’” Id. (quoting Securities & Exchange Comm’n v. Dresser Indus., 628 F.2d 1368, 13 1374 (D.C. Cir. 1980)). “Nevertheless, a court may decide in its discretion to stay civil 14 proceedings ... ‘when the interests of justice seem[ ] to require such action.’” Id. (quoting 15 Dresser, 628 F.2d at 1375). 16 A. Motion to Stay Pursuant to Heck and Wallace 17 In Heck, the Supreme Court held: 18 [T]o recover damages for an allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose lawfulness 19 would render a conviction or sentence invalid, a § 1983 plaintiff must prove that the conviction or sentence has been reversed on direct 20 appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into 21 question by a federal court's issuance of a writ of habeas corpus[.] 22 512 U.S. at 486-87. 23 Heck does not bar plaintiff from bringing an action raising claims challenging ongoing 24 criminal proceedings. However, Wallace explains that such an action should be stayed: 25 [i]f plaintiff files a false-arrest claim before he [or she] has been convicted (or files any other claim related to rulings that likely will 26 be made in a pending or anticipated criminal trial), it is within the power of the district court, and in accord with common practice, to 27 stay the civil action until the criminal case or the likelihood of a criminal case is ended. 28 1 549 U.S. at 393-94. 2 Later, “[i]f the plaintiff is convicted, and if the stayed civil suit would impugn that 3 conviction, Heck requires dismissal; otherwise, the case may proceed.” Yuan v. City of Los 4 Angeles, 2010 WL 3632810 at *5 (C.D. Cal. Aug. 19, 2010), findings and recommendations 5 adopted by 2010 WL 3632528 (C.D. Cal. Sept. 10, 2010) (citing Wallace, 549 U.S. at 393); 6 Peyton v. Burdick, 358 Fed. Appx. 961, 962 (9th Cir. 2009) (vacating judgment in a § 1983 case 7 where claims implicated rulings likely to be made in pending state court criminal proceedings and 8 remanding for district court to stay action until pending state court proceedings concluded); 9 Valenzuela v. Santiesteban, 2021 WL 1845544, at *1-3 (E.D. Cal. Apr. 9, 2021) (staying 10 excessive force case where related criminal prosecution pending); Vivas v. County of Riverside, 11 2016 WL 9001020, at *3 (C.D. Cal. Jan. 12, 2016) (staying excessive force case where criminal 12 prosecution for resisting arrest was pending). 13 When determining whether a stay is appropriate, courts look to whether the criminal 14 defendant’s Fifth Amendment rights may be implicated by the civil proceedings. Keating, 45 15 F.3d at 324; see also Fed.

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Related

Landis v. North American Co.
299 U.S. 248 (Supreme Court, 1936)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Kelly v. Robinson
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Pennzoil Co. v. Texaco Inc.
481 U.S. 1 (Supreme Court, 1987)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Clinton v. Jones
520 U.S. 681 (Supreme Court, 1997)
Wallace v. Kato
127 S. Ct. 1091 (Supreme Court, 2007)
Nken v. Holder
556 U.S. 418 (Supreme Court, 2009)
Dependable Highway Express, Inc. v. Navigators Ins.
498 F.3d 1059 (Ninth Circuit, 2007)
Aurelius Peyton v. Jeffrey Burdick
358 F. App'x 961 (Ninth Circuit, 2009)
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Bluebook (online)
(PC) Gates v. Sergent, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-gates-v-sergent-caed-2024.