(PC) Owens v. Brewer

CourtDistrict Court, E.D. California
DecidedFebruary 10, 2025
Docket2:22-cv-01765
StatusUnknown

This text of (PC) Owens v. Brewer ((PC) Owens v. Brewer) 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) Owens v. Brewer, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 THEON OWENS, No. 2:22-cv-1765 CSK P 12 Plaintiff, 13 v. ORDER AND FINDINGS AND RECOMMENDATIONS 14 A. BREWER, 15 Defendant. 16 17 I. INTRODUCTION 18 Plaintiff is a former state prisoner, proceeding without counsel, with a civil rights action 19 pursuant to 42 U.S.C. § 1983. Pending before the Court is defendant Brewer’s motion to dismiss 20 with prejudice pursuant to 28 U.S.C. § 1915(e)(2)(A) on the grounds that plaintiff made untrue 21 allegations of poverty in plaintiff’s in forma pauperis application. (ECF No. 37.) For the 22 following reasons, this Court recommends that defendant’s motion to dismiss be granted. 23 II. LEGAL STANDARD 24 Pursuant to 28 U.S.C. § 1915(e)(2), notwithstanding any filing fee, or any portion thereof, 25 that may have been paid, the court shall dismiss the case at any time if the court determines that— 26 (A) the allegation of poverty is untrue; or 27 (B) the action or appeal- 28 (i) is frivolous or malicious; 1 (ii) fails to state a claim on which relief may be granted; or 2 (iii) seeks monetary relief against a defendant who is immune from such relief. 3 4 28 U.S.C. § 1915(e)(2). 5 Dismissal under § 1915(e)(2)(A) requires “a showing of bad faith, not merely 6 inaccuracy.” Escobedo v. Applebees, 787 F.3d 1226, 1234 n. 8 (9th Cir. 2015). 7 In Witkin v. Lee, 2020 WL 2512383, at *3-5 (E.D. Cal. May 15, 2020), report and 8 recommendation adopted, 2020 WL 4350094 (E.D. Cal. July 29, 2020), appeal dismissed, 2020 9 WL 8212954 (9th Cir. Dec. 9, 2020), the Court surveyed the relevant cases and summarized the 10 law applicable to dismissals under § 1915(e)(2)(A): 11 Courts have not been totally uniform in their application of § 1915(e)(2)(A), but a close reading of the cases applying the statute 12 reveals consistent considerations guiding the courts’ analyses. The U.S. Court of Appeals for the Ninth Circuit provided a starting point 13 in Escobedo, 787 F.3d at 1234 n.8, stating that, to dismiss a complaint under § 1915(e)(2)(A), the court must find that the 14 allegation of poverty was not just inaccurate, but made in bad faith. Consistent with that approach, other courts have concluded that, 15 where the allegation of poverty is untrue but there is no showing of bad faith, the court should impose a lesser sanction than outright 16 dismissal with prejudice, for example, revoking IFP and provide a window for the plaintiff to pay the filing fee, or dismissing without 17 prejudice. Camp v. Oliver, 798 F.2d 434, 438 (11th Cir. 1986) [discussing application of former section 28 U.S.C. § 1915(d): “the 18 court may …dismiss the case if the allegation of poverty is untrue…”]; Mahone v. Pierce Cnty., 2014 WL 6997734, at *3-4, 19 (W.D. Wash. Dec. 10, 2014); Jacobsen v. Am. Honda Motor Co., 2010 WL 3118364, [D. Or. Apr. 29, 2010] at *3 (recommending 20 dismissal without prejudice where plaintiff failed to disclose income on IFP application but the evidence did not conclusively show 21 intentional misrepresentation). 22 Courts that have declined to dismiss an action under § 1915(e)(2)(A) have generally based their decisions on the actual poverty of the 23 plaintiff, despite a technical inaccuracy in the IFP application, and the absence of a showing of bad faith. Escobedo, 787 F.3d at 1234 24 n.8 (dismissal not warranted where plaintiff claimed to be paying a certain amount in “rent” despite actually owning her home, because 25 her mortgage payment was equivalent to a payment of rent and plaintiff owned no equity in the home); Camp, 798 F.2d at 438-49 26 (reversing district court’s dismissal where there was no finding [of bad faith] and that plaintiff’s inaccuracy foreclosed IFP eligibility); 27 Hammler v. Alvarez, 2019 WL 549627, at *2 (S.D. Cal. Feb. 13, 2019) (dismissal not warranted where plaintiff failed to reveal over 28 $1000 in settlement funds because such funds were immediately and 1 entirely used to pay plaintiff’s restitution fines); Ruffin v. Baldwin, 2018 WL 6266652, at *4 (S.D. Ill. Nov. 30, 2018) (dismissal not 2 warranted where plaintiff did not list over $4,000 in settlement funds received in the six months preceding the application because the 3 funds were revealed on the accompanying trust account statement (indicating no intent to conceal them) and because, by the date of the 4 application, plaintiff had spent the money and was thus eligible for in forma pauperis status); Griffin v. Moon, 2016 WL 8678564, at *3 5 (E.D. Cal. Sept. 23, 2016) (dismissal not warranted where plaintiff had received funds between 8 and 20 years prior to his IFP 6 application and there was no evidence that he currently had such funds). 7 On the flip side, courts routinely dismiss with prejudice cases upon 8 finding that the plaintiff has intentionally withheld information that may have disqualified plaintiff from obtaining IFP status or has 9 otherwise manipulated his finances to make it appear that a plaintiff is poorer than he actually is; i.e., where the facts show that the 10 inaccuracy on the IFP application resulted from the plaintiff’s bad faith. Thus, in Kennedy v. Huibregtse, 831 F.3d 441, 442-44 (7th Cir. 11 2016), the Seventh Circuit affirmed the district court’s dismissal with prejudice of a complaint pursuant to § 1915(e)(2)(A) where the 12 plaintiff failed to reveal that he had a trust account outside of prison, managed by a friend, containing about $1400 at the time of the 13 plaintiff’s IFP application. The court rejected plaintiff’s claim that he did not know the balance of the account at that time and thought it 14 had only about $10, because he spent over $600 from it just before and after the application. Id. at 444. Importantly, the court found 15 that, even if the district court would have granted the plaintiff IFP status if it had known about the trust account, 16 hiding assets is not a permissible alternative to seeking the 17 judge’s assistance. An applicant has to tell the truth, then argue to the judge why seemingly adverse facts (such as the 18 trust fund in this case) are not dispositive. A litigant can't say, “I know how the judge should rule, so I'm entitled to conceal 19 material information from him.” 20 Id. at 443 (emphasis in original). 21 Similarly, the Seventh Circuit affirmed a dismissal with prejudice under § 1915(e)(2)(A) where the plaintiff had not disclosed a savings 22 account he controlled with a balance of over $32,000 at the time of his IFP application. David v. Wal-Mart Stores, Inc., 669 F. App’x 23 793 (7th Cir. 2016). The court rejected the plaintiff’s explanation that he regarded the account as off-limits because he kept that money for 24 his family in case of financial hardship. Id. at 794. The plaintiff had used funds from the account to pay $600 for a seminar and thus his 25 claim that he could not have used the money for the filing fee was disingenuous. Id. And, as in Kennedy, the court emphasized that the 26 plaintiff must disclose assets to the court and allow the court to assess their availability to him. Id. at 794. 27 The Second Circuit reached the same conclusion in Vann v. Comm’r 28 of the N.Y.C. Dep’t of Corr., 496 F. App’x 113 (2d Cir.

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Bluebook (online)
(PC) Owens v. Brewer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-owens-v-brewer-caed-2025.