(PC) Hayes-Kelly v. Curry

District Court, E.D. California·Decided June 9, 2023·No. 2:23-cv-00585·Unknown

Opinion

NICHOLAS K. HAYES-KELLY, No. 2:23-cv-00585-DAD-EFB (PC) Plaintiff, v. ORDER CLINTON J. CURRY, et al., Defendants. Plaintiff is a county jail inmate proceeding without counsel in an action brought under 42 U.S.C. § 1983. In addition to filing a complaint, plaintiff has filed an application to proceed in forma pauperis pursuant to 28 U.S.C. § 1915. Leave to Proceed In Forma Pauperis Plaintiff’s application makes the showing required by 28 U.S.C. § 1915(a)(1) and (2). Accordingly, by separate order, the court directs the agency having custody of plaintiff to collect and forward the appropriate monthly payments for the filing fee as set forth in 28 U.S.C. § 1915(b)(1) and (2). Screening Standards Federal courts must engage in a preliminary screening of cases in which prisoners seek redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The court must identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint “is frivolous, malicious, or fails to state a claim upon which relief may be granted,” or “seeks monetary relief from a defendant who is immune from such relief.” Id. § 1915A(b). A pro se plaintiff, like other litigants, must satisfy the pleading requirements of Rule 8(a) of the Federal Rules of Civil Procedure. Rule 8(a)(2) “requires a complaint to include a short and plain statement of the claim showing that the pleader is entitled to relief, in order to give the defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 554, 562-563 (2007) (citing Conley v. Gibson, 355 U.S. 41 (1957)). While the complaint must comply with the “short and plaint statement” requirements of Rule 8, its allegations must also include the specificity required by Twombly and Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). To avoid dismissal for failure to state a claim a complaint must contain more than “naked assertions,” “labels and conclusions” or “a formulaic recitation of the elements of a cause of action.” Twombly, 550 U.S. at 555-557. In other words, “[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. Furthermore, a claim upon which the court can grant relief must have facial plausibility. Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. When considering whether a complaint states a claim upon which relief can be granted, the court must accept the allegations as true, Erickson v. Pardus, 551 U.S. 89 (2007), and construe the complaint in the light most favorable to the plaintiff, see Scheuer v. Rhodes, 416 U.S. 232, 236 (1974). Screening Order The complaint alleges that on August 18, 2019, Yuba County Sheriff Deputy Tyler Johannes arrested plaintiff “for a weapon [he] did not have and a crime [he] did not commit despite proof of innocence.” ECF No. 1 at 3. It further alleges that Ashley Tuft, of the Yuba County District Attorney’s Office, held plaintiff in jail until November 17, 2019. Id. Plaintiff seeks $150,000 in compensatory damages for emotional distress caused by this “false imprisonment.” Id. In addition to naming deputy Johannes and the District Attorney’s Office, plaintiff also names the County of Yuba as a defendant. Id. at 1. As discussed below, there are three problems with this complaint requiring that it be dismissed. First, the underlying claim of false arrest/false imprisonment is Heck-barred.1 Heck holds that if success in a section 1983 action would implicitly question the validity of confinement or its duration, the plaintiff must first show that the underlying conviction was reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal, or questioned by the grant of a writ of habeas corpus. Muhammad v. Close, 540 U.S. 749, 751 (2004); Heck v. Humphrey, 512 U.S. 477, (1994). In any amended complaint, plaintiff should allege why he was released from jail on November 17, 2019, and whether the weapon charge against him was dropped. Second, Yuba County can only be liable if plaintiff’s purported injuries were caused by an officer acting pursuant to a County policy or custom. See Mt. Healthy City Sch. Dist. Bd. of Ed. v. Doyle, 429 U.S. 274, 280 (1977); Monell v. New York City Dep’t of Soc. Servs., 436 U.S. 658, 691 (1978); Villegas v. Gilroy Garlic Festival Ass'n, 541 F.3d 950, 964 (9th Cir. 2008). Plaintiff does not allege the existence of any County policy, nor does he allege that his false arrest/false imprisonment was caused by defendant Johannes’s implementation or adherence to any County policy. Third, prosecutors are absolutely immune from civil suits for damages under § 1983 which challenge activities related to the initiation and presentation of criminal prosecutions. Imbler v. Pachtman, 424 U.S. 409, 427-28 (1976). This extends to prosecutorial conduct during pretrial proceedings. See Buckley v. Fitzsimmons, 509 U.S. 259, 273 (1993) (“We have not retreated, however, from the principle that acts undertaken by a prosecutor in preparing for the initiation of judicial proceedings or for trial, and which occur in the course of his role as an

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Buckley v. Fitzsimmons
509 U.S. 259 (Supreme Court, 1993)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Muhammad v. Close
540 U.S. 749 (Supreme Court, 2004)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Richard E. Loux v. B. J. Rhay, Warden
375 F.2d 55 (Ninth Circuit, 1967)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Villegas v. Gilroy Garlic Festival Ass'n
541 F.3d 950 (Ninth Circuit, 2008)
Sloman v. Tadlock
21 F.3d 1462 (Ninth Circuit, 1994)
Johnson v. Duffy
588 F.2d 740 (Ninth Circuit, 1978)