(PS) Cowan v. United States Department of Health & Human Services

District Court, S.D. California·Decided October 9, 2025·No. 3:25-cv-02100·Unknown

Opinion

LATAWNYA COWAN, Case No. 25-cv-2100-BAS-BJW

Plaintiff, ORDER: v. (1) GRANTING MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS HEALTH & HUMAN SERVICES, et al., (ECF No. 2); AND Defendants. (2) DISMISSING ACTION WITHOUT PREJUDICE FOR FAILING TO STATE A CLAIM UNDER 28 U.S.C. § 1915 (ECF No. 1)

Plaintiff Latawnya Cowan is proceeding pro se, without an attorney. She filed a complaint on April 22, 2025, against federal and state entities as well as named individuals. (ECF No. 1.) Plaintiff seeks damages and requests a jury trial. (Id.) Plaintiff filed a motion seeking leave to proceed in forma pauperis (“IFP”)—without prepaying court fees or costs. (ECF No. 2.) Plaintiff originally filed her complaint and IFP motion in the United States District Court for the Eastern District of California using a non- prisoner form complaint. (ECF No. 1.) On August 15, 2025, the action was transferred to this Court. (ECF No. 3.) For the following reasons, the Court GRANTS Plaintiff’s motion to proceed IFP and DISMISSES with leave to amend her complaint. All parties instituting any civil action, suit, or proceeding in a district court of the United States, except an application for writ of habeas corpus, must pay a filing fee. See 28 U.S.C. § 1914. Under 28 U.S.C. § 1915, a litigant who because of indigency is unable to pay the required fee or security to commence a legal action may petition the court to proceed without making such payment. To satisfy the requirements of 28 U.S.C. § 1915, “an affidavit [of poverty] is sufficient which states that one cannot because of his poverty pay or give security for the costs . . . and still be able to provide himself and dependents with the necessities of life.” Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 (1948) (citation modified). Having read and considered Plaintiff’s application, the Court finds that Plaintiff meets the requirements for indigency pursuant to 28 U.S.C. § 1915. Here, Plaintiff has no assets. (ECF No. 2.) Further, she takes care of dependents and receives no child support. (Id.) Under these circumstances, the Court finds that requiring Plaintiff to pay the filing fee would impair her ability to obtain the necessities of life. Thus, the Court GRANTS Plaintiff’s request to proceed IFP. (ECF No. 2.) II. SCREENING UNDER 28 U.S.C. § 1915 Under 28 U.S.C. § 1915(e)(2)(B), courts must sua sponte dismiss IFP complaints, or any portions thereof, which are frivolous, malicious, fail to state a claim, or which seek damages from defendants who are immune. See 28 U.S.C. § 1915(e)(2)(B). “The standard for determining whether a plaintiff has failed to state a claim upon which relief can be granted under § 1915(e)(2)(B)(ii) is the same as the Federal Rule of Civil Procedure 12(b)(6) standard for failure to state a claim.” Watison v. Carter, 668 F.3d 1108, 1112 (9th Cir. 2012). Rule 12(b)(6) requires a complaint to “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). Plaintiff’s complaint names several Defendants: (1) the United States Department of Health and Human Services (doing business as San Diego County Health and Human Services); (2) the County of San Diego; as well as (3) Kimberly Giardina (the San Diego HHS Director) and Julia Ramzi (a Social Worker). (ECF No. 1.) Plaintiff appears to raise several causes of action, including 42 U.S.C. § 1983 and the Americans with Disabilities Act (“ADA”). (Id.) For relief, Plaintiff seeks damages, specifically: 25 million dollars, punitive damages, damages under California’s Unruh Act, any damages awarded by a jury, and underpayment in all federal or state benefits. (Id.) She lists the following injuries in her complaint: lost wages, emotional distress, loss of quality of life, inconvenience, medical expenses, and loss of property. (Id.) The complaint does not explicitly assert a basis for the Court’s jurisdiction. (Id.) Nevertheless, by alleging that Defendants violated her rights under 42 U.S.C. § 1983, Plaintiff in substance alleges federal question jurisdiction. 18 U.S.C. § 1331. The Court now analyzes each cause of action. A. Section 1983 Plaintiff’s complaint alleges violations of the First, Eighth, and Fourteenth Amendments under 42 U.S.C. § 1983. For each Defendant, the Court addresses whether Plaintiff can bring suit and seek relief. To the extent Plaintiff may seek relief, the Court addresses whether Plaintiff has stated a claim for relief. First, to the extent Plaintiff seeks to sue the United States Department of Health and Human Services (doing business as San Diego County Health and Human Services), her complaint fails because federal agencies cannot be sued under 42 U.S.C. § 1983. See Cabrera v. Martin, 973 F.2d 735, 743 (9th Cir. 1992). Accordingly, Plaintiff’s § 1983 claim against Defendant United States Department of Health and Human Services shall be dismissed without leave to amend. Second, to the extent Plaintiff names the County of San Diego as a Defendant, a county can only be held liable under § 1983 when a custom or policy gives rise to a constitutional deprivation. See Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658, 690 (1978). But a county cannot be sued under a theory of respondeat superior liability, for example “a municipality cannot be held liable solely because it employs a tortfeasor.” Id. at 691. Moreover, a county can be held liable when a failure to train or supervise amounts to deliberate indifference of an individual’s rights. See City of Canton, Ohio v. Harris, 489 U.S. 378, 389–90 (1989). Here, Plaintiff has not pointed to a formal policy or longstanding custom that caused her alleged constitutional injuries. Nor has Plaintiff pointed to a failure to train or supervise. Accordingly, Plaintiff’s § 1983 claim against Defendant County of San Diego shall be dismissed with leave to amend. Third, Plaintiff seeks to sue S

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(PS) Cowan v. United States Department of Health & Human Services, (S.D. Cal. 2025).

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