(PC) Whitsitt v. San Joaquin County Mental Health

CourtDistrict Court, E.D. California
DecidedMay 11, 2022
Docket2:22-cv-00356
StatusUnknown

This text of (PC) Whitsitt v. San Joaquin County Mental Health ((PC) Whitsitt v. San Joaquin County Mental Health) 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) Whitsitt v. San Joaquin County Mental Health, (E.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 WILLIAM J. WHITSITT, No. 2:22-cv-00356-WBS-CKD P 12 Plaintiff, 13 v. ORDER 14 SAN JOAQUIN COUNTY MENTAL HEALTH, et al., 15 Defendants. 16

18 Plaintiff is a county prisoner proceeding pro se and seeking relief pursuant to 42 U.S.C. § 19 1983. This proceeding was referred to this court by Local Rule 302 pursuant to 28 U.S.C. § 20 636(b)(1). 21 Plaintiff requests leave to proceed in forma pauperis. As plaintiff has submitted a 22 declaration that makes the showing required by 28 U.S.C. § 1915(a), his request will be granted. 23 Plaintiff is required to pay the statutory filing fee of $350.00 for this action. 28 U.S.C. §§ 24 1914(a), 1915(b)(1). By separate order, the court will direct the appropriate agency to collect the 25 initial partial filing fee from plaintiff’s trust account and forward it to the Clerk of the Court. 26 Thereafter, plaintiff will be obligated for monthly payments of twenty percent of the preceding 27 month’s income credited to plaintiff’s prison trust account. These payments will be forwarded by 28 1 the appropriate agency to the Clerk of the Court each time the amount in plaintiff’s account 2 exceeds $10.00, until the filing fee is paid in full. 28 U.S.C. § 1915(b)(2). 3 I. Screening Requirement 4 The court is required to screen complaints brought by prisoners seeking relief against a 5 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 6 court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 7 “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek 8 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1),(2). 9 A claim is legally frivolous when it lacks an arguable basis either in law or in fact. 10 Neitzke v. Williams, 490 U.S. 319, 325 (1989); Franklin v. Murphy, 745 F.2d 1221, 1227-28 (9th 11 Cir. 1984). The court may, therefore, dismiss a claim as frivolous where it is based on an 12 indisputably meritless legal theory or where the factual contentions are clearly baseless. Neitzke, 13 490 U.S. at 327. The critical inquiry is whether a constitutional claim, however inartfully 14 pleaded, has an arguable legal and factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th 15 Cir. 1989); Franklin, 745 F.2d at 1227. 16 In order to avoid dismissal for failure to state a claim a complaint must contain more than 17 “naked assertions,” “labels and conclusions” or “a formulaic recitation of the elements of a cause 18 of action.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-557 (2007). In other words, 19 “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory 20 statements do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Furthermore, a claim 21 upon which the court can grant relief has facial plausibility. Twombly, 550 U.S. at 570. “A 22 claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw 23 the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. 24 at 678. When considering whether a complaint states a claim upon which relief can be granted, 25 the court must accept the allegations as true, Erickson v. Pardus, 127 S. Ct. 2197, 2200 (2007), 26 and construe the complaint in the light most favorable to the plaintiff, see Scheuer v. Rhodes, 416 27 U.S. 232, 236 (1974). 28 ///// 1 II. Allegations in the Complaint 2 Plaintiff is a pretrial detainee at the San Joaquin County Jail. In his original complaint 3 plaintiff attempts to sue various defendants for engaging in a “RICO criminal enterprise and 4 conspiracy.” ECF No. 1 at 1. However, before the court could screen this complaint, plaintiff 5 filed a series of amended complaints. ECF Nos. 7, 9, 10. 6 III. Legal Standards 7 The following legal standards are being provided to plaintiff based on his pro se status as 8 well as the nature of the allegations in his complaint. 9 A. State Actor Requirement 10 Section 1983 “provides a cause of action for the deprivation of any rights, privileges, or 11 immunities secured by the Constitution and laws of the United States.” Wilder v. Virginia Hosp. 12 Ass'n, 496 U.S. 498, 508 (1990) (quoting 42 U.S.C. § 1983). To state a claim under § 1983, a 13 plaintiff must allege a violation of a right secured by the Constitution or laws of the United States 14 committed by a person acting under the color of state law. See West v. Atkins, 487 U.S. 42, 48 15 (1988); Ketchum v. Alameda Cnty., 811 F.2d 1243, 1245 (9th Cir. 1987). Thus, private 16 individuals, such as those named in plaintiff’s complaint, are not proper defendants in a § 1983 17 action. 18 B. Criminal Actions Not Cognizable 19 Although plaintiff seeks to hold defendants liable for various alleged criminal acts, 20 plaintiff provides no authority for the proposition that he has a private right of action to assert a 21 violation of criminal statutes, and no such right generally exists. See Aldabe v. Aldabe, 616 F.2d 22 1089, 1092 (9th Cir. 1980) (holding specific criminal provisions in the United States Code 23 “provide no basis for civil liability”); Ellis v. City of San Diego, 176 F.3d 1183, 1189 (9th Cir. 24 1999) (“sections of the California Penal Code ... do not create enforceable individual rights”). 25 Unless there is a clear congressional intent to provide a civil remedy, a plaintiff cannot recover 26 civil damages for an alleged violation of a criminal statute. Federal Sav. & Loan Ins. Corp. v. 27 Reeves, 816 F.2d 130, 138 (4th Cir. 1987) (where there is no affirmative indication that Congress 28 intended to furnish a civil remedy, no civil cause of action exists). 1 C. Retaliation 2 Prison officials generally cannot retaliate against inmates for exercising First Amendment 3 rights. Rizzo v. Dawson, 778 F.2d 527, 531 (9th Cir. 1985).

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490 U.S. 319 (Supreme Court, 1989)
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496 U.S. 498 (Supreme Court, 1990)
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Bell Atlantic Corp. v. Twombly
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(PC) Whitsitt v. San Joaquin County Mental Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-whitsitt-v-san-joaquin-county-mental-health-caed-2022.