(PS) Ben-Oni v. Wood

CourtDistrict Court, E.D. California
DecidedApril 3, 2025
Docket2:24-cv-02769
StatusUnknown

This text of (PS) Ben-Oni v. Wood ((PS) Ben-Oni v. Wood) 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
(PS) Ben-Oni v. Wood, (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 JOSIAH MALCHIEL ISRAEL BEN-ONI, Case No. 2:24-cv-2769-DJC-JDP (PS) 12 Plaintiff, 13 v. ORDER 14 JONATHAN LUKE WOOD, et al., 15 Defendants. 16 17 Plaintiff is a current student at California State University, Sacramento (“CSUS”). He has 18 brought this case against Jonathan Wood, the President of the University; and the University’s 19 student body group, the Associated Students, Incorporated (“ASI”). Pending are plaintiff’s: 20 motion for class certification, ECF No. 24; motion to file supplemental pleadings, ECF No. 29; 21 request for a status conference, ECF No. 31; request for procedural clarity, ECF No. 36; motion 22 for a hearing date, ECF No. 37; revised motion for a hearing date, ECF No. 40; motion to file a 23 supplemental brief, ECF No. 41; corrected motion to file a supplemental brief, ECF No. 42; 24 motion for leave to file a sur-reply, ECF No. 45; and motion to appoint counsel, ECF No. 46. 25 Defendants have filed a motion to dismiss, ECF No. 33. For the foregoing reasons, each of 26 plaintiff’s motions are denied and defendants’ motion is granted without prejudice. 27 28 1 Motion for Class Certification 2 Plaintiff has filed a motion that asks for this case to proceed as a class action. The motion 3 also seeks to certify a class consisting of current and former students at CSUS who paid tuition 4 during the 2023-2024 academic year. ECF No. 24. Defendants oppose this motion. ECF No. 32. 5 Because plaintiff is representing himself, he cannot litigate a class action on behalf of other 6 plaintiffs. See C.E. Pope Equity Trust v. United States, 818 F.2d 696, 697 (9th Cir. 1987) 7 (holding that a pro se litigant may not appear as an attorney for others); Antonetti v. Foster, 691 F. 8 App’x 841, 841 (9th Cir 2017) (unpublished) (“The district court properly denied Antonetti’s 9 motion for class certification because, as a pro se litigant, Antonetti has no authority to represent 10 anyone other than himself.”). This motion is denied. And since this motion is denied, so too is 11 plaintiff’s motion for a hearing on the motion and his motion to revise the hearing date. ECF 12 Nos. 37 & 40. 13 Motions for Supplemental Filings 14 Plaintiff has filed a motion to file a supplemental pleading that adds additional claims, 15 ECF No. 29; a motion to file a supplemental brief, ECF No. 41; a corrected motion to file a 16 supplemental brief, ECF No. 42; and a motion to file a sur-reply, ECF No. 45. The motion to file 17 a supplemental pleading is denied as unnecessary since, as explained below, plaintiff will be 18 permitted to file an amended complaint within thirty days of this order. The motions to file 19 supplemental briefs are denied because plaintiff does not explain what brief he seeks to 20 supplement. Finally, plaintiff’s motion to file a sur-reply is denied as unnecessary as the court 21 resolves defendants’ motion to dismiss in this order. 22 Motion for a Status Conference 23 Plaintiff requests a status conference be held to address his pending motions. ECF No. 31. 24 That motion is denied as moot as this order resolves all pending motions. 25 Motion for Procedural Clarity 26 In this motion, plaintiff requests that the court order defendants to file separate motions to 27 dismiss. ECF No. 36 at 1-2. Additionally, plaintiff asks that the court direct defendants to 28 address the “substantive implications” rather than “procedural arguments” in their motion to 1 dismiss. Id. at 3. This motion is denied. Plaintiff has sued both defendants in the same lawsuit; 2 there is no requirement that they file separate motions. 3 Motion for Counsel 4 Generally, pro se litigants do not have a right to counsel in civil actions. Palmer v. 5 Valdez, 560 F.3d 965, 970 (9th Cir. 2009). However, the court can ask that an attorney represent 6 an indigent civil litigant under certain exceptional circumstances. 28 U.S.C. § 1915(e)(1) (“The 7 court may request an attorney to represent any person unable to afford counsel”); see Agyeman v. 8 Corrections Corp. of America, 390 F.3d 1101, 1103 (9th Cir 2004). In determining whether such 9 circumstances exist, the court must evaluate both the plaintiff’s likelihood of “success on the 10 merits and . . . plaintiff’s ability to articulate his claims in light of the complexity of the legal 11 issues involved.” Agyeman, 390 F.3d at 1103 (internal quotation omitted). 12 The court does not find that plaintiff’s likelihood of success, the complexity of the issues, 13 or the degree of plaintiff’s ability to articulate his claims amount to exceptional circumstances 14 warranting the appointment of counsel. Accordingly, this motion is denied. ECF No. 46. 15 Motion to Dismiss 16 I. Allegations 17 Plaintiff brings this action against defendant Wood, in his official capacity as President of 18 CSUS and the ASI of CSUS. ECF No. 25 at 3-4. ASI is a student organization that represents 19 student interests, manages student activities, and is a self-governing organization. Id. at 4. The 20 34-page amended complaint details many specific, but not necessarily related, grievances plaintiff 21 has against defendants; but the court understands the crux of plaintiff’s claims to center around 22 his ineligibility to author petitions that would have blocked ASI’s representatives from raising the 23 ASI membership fee. 24 Plaintiff alleges that on April 13, 2023, ASI relied upon ASI Operating Rule 200.6 to deny 25 him the right to create or sign a petition to recall the president and vice president of ASI. Id. 26 Rule 200.6 mandates that eligibility to sign a petition rest on whether the student participated in a 27 prior election. Id. Plaintiff claims that ASI’s use of Rule 200.6 violates CSUS’s 28 nondiscrimination policy because it “disenfranchises” transfer students, freshman, international 1 students, and undocumented students. Id. He claims that this denial occurred during a critical 2 election, in which defendant Wood tasked ASI to increase ASI membership fees. Id. Plaintiff 3 attributes the low student voter turnout in the Spring 2023 elections to the “chilling effect” of 4 Rule 200.6. Id. at 5. Plaintiff attempted to initiate a second recall petition of the ASI president 5 and vice president in April 2024, but his ability was “severely hampered” by Rule 200.6. Id. at 6. 6 The ASI president and vice president, with the support of defendant Wood, increased the ASI fee 7 to $508. Id. at 5. This increase, according to the complaint, disproportionally affects low-income 8 and underrepresented students.1 Id. at 9. 9 Plaintiff alleges that defendants violated his First, Eighth, and Fourteenth Amendment 10 rights. Id. at 6-7. For his First Amendment claim, plaintiff alleges that ASI’s implementation of 11 Rule 200.6 had a chilling effect and constituted an unlawful restriction on constitutionally 12 protected speech. Id. at 6. Plaintiff alleges that Rule 200.6’s discriminatory nature violates the 13 Equal Protection Clause by prohibiting marginalized groups (transfer students, freshman, 14 international, undocumented students) from participating in ASI’s voting. Id. Next, he claims 15 that ASI’s implementation of Rule 200.6 violates due process since the rule fails to provide notice 16 to students about their eligibility to participate in elections. Id. at 7. Finally, he claims that 17 defendant Wood’s lack of action to address the discriminatory nature of Rule 200.6 constitutes 18 deliberate indifference. 19 II.

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Bluebook (online)
(PS) Ben-Oni v. Wood, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-ben-oni-v-wood-caed-2025.