(PS) Cowan v. State of CA Dept. of Social Services

CourtDistrict Court, E.D. California
DecidedMay 2, 2025
Docket2:25-cv-00697
StatusUnknown

This text of (PS) Cowan v. State of CA Dept. of Social Services ((PS) Cowan v. State of CA Dept. of Social Services) 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) Cowan v. State of CA Dept. of Social Services, (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 LATAWNYA COWAN, No. 2:25-cv-0697 DJC AC PS 12 Plaintiff, 13 v. ORDER 14 STATE OF CALIFORNIA DEPARTMENT OF SOCIAL SERVICES, 15 et al., 16 Defendants. 17 18 Plaintiff is proceeding in this action pro se. This matter was accordingly referred to the 19 undersigned by E.D. Cal. 302(c)(21). Plaintiff has filed a request for leave to proceed in forma 20 pauperis (“IFP”) and submitted the affidavit required by that statute. See 28 U.S.C. § 1915(a)(1). 21 The motion to proceed IFP (ECF No. 5, duplicate filed at ECF No. 8) will therefore be granted. 22 Plaintiff also filed two motions for appointment of counsel (ECF Nos. 3 and 6) and a motion to e- 23 file (ECF No. 7). These motions are denied, for the reasons explained below. 24 I. SCREENING 25 A. Legal Standard 26 The federal IFP statute requires federal courts to dismiss a case if the action is legally 27 “frivolous or malicious,” fails to state a claim upon which relief may be granted or seeks 28 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2). 1 Plaintiff must assist the court in determining whether the complaint is frivolous, by drafting the 2 complaint so that it complies with the Federal Rules of Civil Procedure (“Fed. R. Civ. P.”). The 3 Federal Rules of Civil Procedure are available online at www.uscourts.gov/rules-policies/current- 4 rules-practice-procedure/federal-rules-civil-procedure. 5 Under the Federal Rules of Civil Procedure, the complaint must contain (1) a “short and 6 plain statement” of the basis for federal jurisdiction (that is, the reason the case is filed in this 7 court, rather than in a state court), (2) a short and plain statement showing that plaintiff is entitled 8 to relief (that is, who harmed the plaintiff, and in what way), and (3) a demand for the relief 9 sought. Fed. R. Civ. P. 8(a). Plaintiff’s claims must be set forth simply, concisely and directly. 10 Fed. R. Civ. P. 8(d)(1). Forms are available to help pro se plaintiffs organize their complaint in 11 the proper way. They are available at the Clerk’s Office, 501 I Street, 4th Floor (Rm. 4-200), 12 Sacramento, CA 95814, or online at www.uscourts.gov/forms/pro-se-forms. 13 A claim is legally frivolous when it lacks an arguable basis either in law or in fact. 14 Neitzke v. Williams, 490 U.S. 319, 325 (1989). In reviewing a complaint under this standard, the 15 court will (1) accept as true all of the factual allegations contained in the complaint, unless they 16 are clearly baseless or fanciful, (2) construe those allegations in the light most favorable to the 17 plaintiff, and (3) resolve all doubts in the plaintiff’s favor. See Neitzke, 490 U.S. at 327; Von 18 Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960 (9th Cir. 2010), cert. 19 denied, 564 U.S. 1037 (2011). 20 The court applies the same rules of construction in determining whether the complaint 21 states a claim on which relief can be granted. Erickson v. Pardus, 551 U.S. 89, 94 (2007) (court 22 must accept the allegations as true); Scheuer v. Rhodes, 416 U.S. 232, 236 (1974) (court must 23 construe the complaint in the light most favorable to the plaintiff). Pro se pleadings are held to a 24 less stringent standard than those drafted by lawyers. Haines v. Kerner, 404 U.S. 519, 520 25 (1972). However, the court need not accept as true conclusory allegations, unreasonable 26 inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 618, 27 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does not suffice 28 //// 1 to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); Ashcroft v. Iqbal, 2 556 U.S. 662, 678 (2009). 3 To state a claim on which relief may be granted, the plaintiff must allege enough facts “to 4 state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has 5 facial plausibility when the plaintiff pleads factual content that allows the court to draw the 6 reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 7 678. A pro se litigant is entitled to notice of the deficiencies in the complaint and an opportunity 8 to amend, unless the complaint’s deficiencies could not be cured by amendment. See Noll v. 9 Carlson, 809 F.2d 1446, 1448 (9th Cir. 1987), superseded on other grounds by statute as stated in 10 Lopez v. Smith, 203 F.3d 1122 (9th Cir.2000)) (en banc). 11 B. The Complaint 12 Plaintiff sues multiple defendants stating that they acted under color of law to violate her 13 rights under 42 U.S.C. § 1983 and several other federal laws. ECF No. 1 at 1-2. Plaintiff writes 14 that her rights were violated because she was denied accommodations, policy modifications, and 15 other forms of assistance. ECF No. 1 at 2. The complaint consists of a single long paragraph that 16 does not contain any facts, but alleges in conclusory terms that plaintiff was denied various forms 17 of assistance, protection, and relief. Id. Plaintiff provides a Missouri address for herself, but 18 states that she moved to California in 1996 and has “participated in CA State Rehabilitations 19 Services f/t Blind & disabled since that time.” Id. at 1-2. 20 C. Discussion 21 Plaintiff’s complaint cannot be served at this time for several reasons. First, the complaint 22 does not contain a “short and plain” statement setting forth the basis for plaintiff’s claims, 23 plaintiff’s entitlement to relief, or the relief that is sought, even though those things are required 24 by Fed. R. Civ. P. 8(a)(1) (3). The exact nature of what happened to plaintiff is unclear from the 25 complaint, which does not contain any facts. The court cannot tell from examining the complaint 26 what legal wrong was done to plaintiff by whom, or how any alleged harm is connected to the 27 relief plaintiff seeks. It is also unclear when the harm occurred. It is not enough for plaintiff to 28 state that she has been harmed or has been denied services; the complaint must set forth the facts 1 explaining what each defendant did to violate plaintiff’s rights. 2 Because the complaint does not contain any clear factual allegations, the complaint cannot 3 be served.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Palmer v. Valdez
560 F.3d 965 (Ninth Circuit, 2009)
Von Saher v. Norton Simon Museum of Art at Pasadena
592 F.3d 954 (Ninth Circuit, 2010)
McHenry v. Renne
84 F.3d 1172 (Ninth Circuit, 1996)
Lopez v. Smith
203 F.3d 1122 (Ninth Circuit, 2000)
United States ex rel. Gardner v. Madden
352 F.2d 792 (Ninth Circuit, 1965)
Western Mining Council v. Watt
643 F.2d 618 (Ninth Circuit, 1981)
Noll v. Carlson
809 F.2d 1446 (Ninth Circuit, 1987)

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Bluebook (online)
(PS) Cowan v. State of CA Dept. of Social Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-cowan-v-state-of-ca-dept-of-social-services-caed-2025.