(PC) James v. Dominisse

District Court, E.D. California·Decided May 15, 2025·No. 2:24-cv-00448·Unknown

Opinion

RONALD EUGENE JAMES, No. 2:24-cv-00448 DJC SCR P Plaintiff, v. ORDER AND FINDINGS AND RECOMMENDATIONS PAMELA JEAN DOMINISSE, et al., Defendants. Plaintiff is a state inmate proceeding pro se and in forma pauperis with a civil rights action under 42 U.S.C. § 1983. Before the court are plaintiff’s second amended complaint (“SAC”) for screening (ECF No. 18) and request for screening (ECF No. 22). Plaintiff’s request of screening is granted. For the reasons set forth below, the undersigned finds that plaintiff’s SAC fails to state a claim for relief and recommends the action be dismissed without leave to amend. The court is required to screen complaints brought by prisoners seeking relief against “a governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A(a). In performing this screening function, the court must dismiss any claim that “(1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant who is immune from such relief.” Id. § 1915A(b). A claim is legally frivolous when it lacks an arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). The court may dismiss a claim as frivolous if it is based on an indisputably meritless legal theory or factual contentions that are baseless. Neitzke, 490 U.S. at 327. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable legal and factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989). In order 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.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-557 (2007). In other words, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A claim upon which the court can grant relief has 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, the court must accept the allegations as true, Erickson v. Pardus, 551 U.S. 89, 93-94 (2007), and construe the complaint in the light most favorable to the plaintiff, Scheuer v. Rhodes, 416 U.S. 232, 236 (1974). In its prior screening order, the court determined that plaintiff’s first amended complaint (“FAC”) did not state a § 1983 claim for damages against any of the attorney-defendants and its requests for declaratory and injunctive relief was barred by the doctrine of Younger v. Harris, 401 U.S. 37, 43-54 (1971). (ECF No. 15.) The court allowed plaintiff 30 days to file an amended complaint that cured the deficiencies. When more than 30 days passed without a response, the court issued an order to show cause why the case should not be dismissed for failure to obey a court order and failure to prosecute. (ECF No. 17.) Plaintiff then filed his SAC and a subsequent response explaining that he had timely filed the SAC but was having “challenges” with the jail’s mail system. (ECF No. 19 at 1-2.) For good cause shown, the order to show cause is discharged. I. Factual Allegations Plaintiff’s SAC challenges the actions and omissions of defendant-attorneys during three of his criminal proceedings, Case Nos. 19FE014992, 19FE014994, and 19FE021761. (ECF No. 18.) It names as defendants a public defender, two conflict criminal attorneys, and the estate of a deceased conflict criminal attorney. (Id. at 2.) Plaintiff alleges that his attorneys allowed prosecutors to associate him with another case that put him at risk of harm from other inmates and failed to object to prosecutors’ request for extensions of time to locate witnesses. (Id. 4-5.) Throughout the state court proceedings, defendants waived plaintiff’s statutory and constitutional rights without his consent. (Id. at 6-10.) For instance, defendants sought their own extensions of time without his consent, thereby denying his right to a speedy trial. (Id. at 6-8.) Plaintiff alleges defendants’ actions constitute breach of fiduciary duties under the Fourteenth Amendment, gross negligence, and legal malpractice. (ECF No. 18 at 4-10). He suffered injuries as a result, including defamation, extreme emotional and mental stress, and anxiety. He requests a declaration that the acts and omissions described herein violated his rights under federal and state law, court costs, compensatory and punitive damages against each defendant, and any other relief the court deems “just, proper, and equitable.” (Id. at 11.) I. 42 U.S.C. § 1983 A plaintiff may bring an action under 42 U.S.C. § 1983 to redress violations of “rights, privileges, or immunities secured by the Constitution and [federal] laws” by a person or entity, including a municipality, acting under the color of state law. 42 U.S.C. § 1983. To state a claim under 42 U.S.C. § 1983, a plaintiff must show that (1) a defendant acting under color of state law (2) deprived plaintiff of rights secured by the Constitution or federal statutes. Benavidez v. County of San Diego, 993 F.3d 1134, 1144 (9th Cir. 2021). As the court advised in its prior screening order, plaintiff cannot bring a claim for damages under § 1983 against any attorney assigned to represented him in his criminal cases. A public defender representing a client in the lawyer’s traditional adversarial role is not a state actor for purposes of § 1983. See Vermont v. Brillon, 556 U.S. 81, 91 (2009) (“assigned counsel ordinarily is not considered a state actor”) (citing Polk County v. Dodson, 454 U.S. 312 (1981)). The acts and omissions that plaintiff complains of here all pertain to their “traditional adversarial roles” in his state criminal proceedings. Plaintiff does not allege any other conduct by defendants that would qualify as actions under color of state law for purposes of § 1983. See Vermont, 556 U.S. at 91 n.7 (public defender may act for state “‘when making hiring and firing decisions on behalf of the State,’ and ‘while performing certain administrative and possibly investigative functions.’” (quoting Polk County, 454 U.S. at 325)). Accordingly, to the extent plaintiff seeks damages from the attorneys assigned to represent him in criminal proceedings, the complaint fails to state a claim for relief. See 28 U.S.C. §

(PC) James v. Dominisse, (E.D. Cal. 2025).

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