(PC) Howard v. Parks

CourtDistrict Court, E.D. California
DecidedMarch 22, 2024
Docket1:24-cv-00285
StatusUnknown

This text of (PC) Howard v. Parks ((PC) Howard v. Parks) 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) Howard v. Parks, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 KARLIS RUBEN AUGUSTUS No. 1:24-cv-00285-SAB (PC) HOWARD, 12 SCREENING ORDER GRANTING Plaintiff, PLAINTIFF LEAVE TO FILE AN 13 AMENDED COMPLAINT v. 14 (ECF No. 1) AYLANA OLIVIA PARKS, et al., 15 Defendants. 16 17 18 Plaintiff is proceeding pro se and in forma pauperis in this action filed pursuant to 42 19 U.S.C. § 1983. 20 Currently before the Court is Plaintiff’s complaint, filed March 7, 2024. 21 I. 22 SCREENING REQUIREMENT 23 The Court is required to screen complaints brought by prisoners seeking relief against a 24 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 25 Court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 26 “frivolous or malicious,” that “fail[] to state a claim on which relief may be granted,” or that 27 “seek[] monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 28 1 1915(e)(2)(B); see also 28 U.S.C. § 1915A(b). 2 A complaint must contain “a short and plain statement of the claim showing that the 3 pleader is entitled to relief. . . .” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not 4 required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere 5 conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell 6 Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Moreover, Plaintiff must demonstrate 7 that each defendant personally participated in the deprivation of Plaintiff’s rights. Jones v. 8 Williams, 297 F.3d 930, 934 (9th Cir. 2002). 9 Prisoners proceeding pro se in civil rights actions are entitled to have their pleadings 10 liberally construed and to have any doubt resolved in their favor. Wilhelm v. Rotman, 680 F.3d 11 1113, 1121 (9th Cir. 2012) (citations omitted). To survive screening, Plaintiff’s claims must be 12 facially plausible, which requires sufficient factual detail to allow the Court to reasonably infer 13 that each named defendant is liable for the misconduct alleged. Iqbal, 556 U.S. at 678-79; Moss 14 v. U.S. Secret Service, 572 F.3d 962, 969 (9th Cir. 2009). The “sheer possibility that a defendant 15 has acted unlawfully” is not sufficient, and “facts that are ‘merely consistent with’ a defendant’s 16 liability” falls short of satisfying the plausibility standard. Iqbal, 556 U.S. at 678; Moss, 572 F.3d 17 at 969. 18 II. 19 DISCUSSION 20 A. Rule 8(a) of the Federal Rules of Civil Procedure 21 Plaintiff’s complaint does not comply with Rule 8. The Court declines to expend its 22 limited resources to review and summarize Plaintiff’s allegations since the complaint clearly 23 violates Rules 8, 18 and 20. 24 Rule 8(a)’s simplified pleading standard applies to all civil actions, with limited 25 exceptions, none of which apply to § 1983 actions. Swierkiewicz v. Sorema, N.A., 534 U.S. 506, 26 512 (2002). Under federal notice pleading, a complaint is required to contain “a short and plain 27 statement of the claim showing that the pleader is entitled to relief ....” Fed. R. Civ. P. 8(a)(2). 28 “Such a statement must simply give defendant fair notice of what the plaintiff's claim is and the 1 grounds upon which it rests.” Id. The federal rules contemplate brevity. See Galbraith v. County 2 of Santa Clara, 307 F.3d 1119, 1125 (9th Cir. 2002) (noting that “nearly all of the circuits have 3 now disapproved any heightened pleading standard in cases other than those governed by Rule 4 9(b)”); Fed. R. Civ. P. 84; cf. Rule 9(b) (setting forth rare exceptions to simplified pleading). Rule 5 8 requires Plaintiff to set forth his claims in short and plain terms, simply, concisely and directly. 6 See Swierkiewicz, 534 U.S. at 514 (“Rule 8(a) is the starting point of a simplified pleading 7 system, which was adopted to focus litigation on the merits of a claim.”); Fed. R. Civ. P. 8. The 8 Court (and each defendant) should be able to read and understand Plaintiff's pleading within 9 minutes. McHenry v. Renne, 84 F.3d 1172, 1179–80 (9th Cir. 1996). 10 Plaintiff's complaint fails to comport with Rule 8(a)’s requirement for “a short and plain 11 statement of the claim showing that the pleader is entitled to relief.” Plaintiff's complaint is 239 12 pages in length and contains a myriad of claims against various defendants based on different 13 events at different institutions spanning over several years. (ECF No. 1.) Plaintiff’s lengthy 14 narrative does not clearly or succinctly allege facts against the named defendants. The Court will 15 grant Plaintiff leave to file a first amended complaint not exceeding 25 pages. The total number of 16 pages, including the form complaint and any exhibits, must not exceed 25 pages. If typewritten, 17 the body of the first amended complaint must be double-spaced. If handwritten, the first amended 18 complaint must be legible and written in reasonably-sized handwriting. Plaintiff should not 19 include legal analysis in the first amended complaint, Plaintiff should endeavor to make it as 20 concise as possible in no more than 25 double-spaced pages. He should merely state which of his 21 constitutional rights he feels were violated by each Defendant or group of Defendants and the 22 factual basis. If Plaintiff fails to comport with these requirements, the first amended complaint 23 may be dismissed or stricken from the record for failure to comply with the Court’s order. 24 B. Joinder of Claims 25 Plaintiff may not bring unrelated claims against unrelated parties in a single action. Fed. 26 R. Civ. P. 18(a), 20(a)(2); Owens v. Hinsley, 635 F.3d 950, 952 (7th Cir. 2011); George v. Smith, 27 507 F.3d 605, 607 (7th Cir. 2007); Mackey v. Price, 2020 WL 7319420, at *3–4 (E.D. Cal. Dec. 28 11, 2020), report and recommendation adopted, 2021 WL 843462 (E.D. Cal. Mar. 5, 2021). 1 Plaintiff may bring a claim against multiple defendants so long as (1) the claim arises out of the 2 same transaction or occurrence, or series of transactions and occurrences, and (2) there are 3 commons questions of law or fact. Fed. R. Civ. P. 20(a)(2); Coughlin v. Rogers, 130 F.3d 1348, 4 1351 (9th Cir. 1997).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Swierkiewicz v. Sorema N. A.
534 U.S. 506 (Supreme Court, 2002)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Campbell, Tom v. Clinton, William J.
203 F.3d 19 (D.C. Circuit, 2000)
Francisco Sanchez v. Esso Standard Oil Co.
572 F.3d 1 (First Circuit, 2009)
Owens v. Hinsley
635 F.3d 950 (Seventh Circuit, 2011)
Jean Patou, Inc. v. Theon, Inc.
9 F.3d 971 (Federal Circuit, 1993)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Moss v. U.S. Secret Service
572 F.3d 962 (Ninth Circuit, 2009)
Abrams Shell v. Shell Oil Co.
165 F. Supp. 2d 1096 (C.D. California, 2001)
Sergio Ramirez v. County of San Bernardino
806 F.3d 1002 (Ninth Circuit, 2015)
McHenry v. Renne
84 F.3d 1172 (Ninth Circuit, 1996)
Coughlin v. Rogers
130 F.3d 1348 (Ninth Circuit, 1997)
Galbraith v. County of Santa Clara
307 F.3d 1119 (Ninth Circuit, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
(PC) Howard v. Parks, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-howard-v-parks-caed-2024.