(PS) Genessi v. Placer County Superior Court

CourtDistrict Court, E.D. California
DecidedJune 10, 2024
Docket2:23-cv-01054
StatusUnknown

This text of (PS) Genessi v. Placer County Superior Court ((PS) Genessi v. Placer County Superior Court) 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) Genessi v. Placer County Superior Court, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 SIOBHAN GENESSI, Case No. 2:23-cv-01054-DAD-JDP (PS) 12 Plaintiff, ORDER 13 v. SCREENING PLAINTIFF’S COMPLAINT AND GRANTING HER MOTION FOR AN 14 PLACER COUNTY SUPERIOR COURT, EXTENSION OF TIME et al., 15 ECF Nos. 10 & 11 Defendants. 16 RESPONSE DUE WITHIN THIRTY DAYS

17 18 Plaintiff Siobhan Genessi has filed a first amended complaint against the Placer County 19 Superior Court, Judge Coleen Nichols, Placer County Child Protective Services, Placer County 20 Counselors Kee Ana Smith and Roger Coffman, and Placer County CPS employee Hilary Trauth. 21 Plaintiff alleges that her due process rights were violated both when her son was removed from 22 her custody and during the pendency of the resulting custody proceeding. Her amended 23 complaint continues to lack allegations sufficient to state a claim. I will give plaintiff a final 24 chance to amend her complaint before recommending dismissal. I will also grant her motion for 25 extension of time and deem her first amended complaint timely. 26 27 28 1 Screening and Pleading Requirements 2 A complaint must contain a short and plain statement that plaintiff is entitled to relief, 3 Fed. R. Civ. P. 8(a)(2), and provide “enough facts to state a claim to relief that is plausible on its 4 face,” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). The plausibility standard does not 5 require detailed allegations, but legal conclusions do not suffice. See Ashcroft v. Iqbal, 556 U.S. 6 662, 678 (2009). If the allegations “do not permit the court to infer more than the mere 7 possibility of misconduct,” the complaint states no claim. Id. at 679. The complaint need not 8 identify “a precise legal theory.” Kobold v. Good Samaritan Reg’l Med. Ctr., 832 F.3d 1024, 9 1038 (9th Cir. 2016). Instead, what plaintiff must state is a “claim”—a set of “allegations that 10 give rise to an enforceable right to relief.” Nagrampa v. MailCoups, Inc., 469 F.3d 1257, 1264 11 n.2 (9th Cir. 2006) (en banc) (citations omitted). 12 The court must construe a pro se litigant’s complaint liberally. See Haines v. Kerner, 404 13 U.S. 519, 520 (1972) (per curiam). The court may dismiss a pro se litigant’s complaint “if it 14 appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which 15 would entitle him to relief.” Hayes v. Idaho Corr. Ctr., 849 F.3d 1204, 1208 (9th Cir. 2017). 16 However, “‘a liberal interpretation of a civil rights complaint may not supply essential elements 17 of the claim that were not initially pled.’” Bruns v. Nat’l Credit Union Admin., 122 F.3d 1251, 18 1257 (9th Cir. 1997) (quoting Ivey v. Bd. of Regents, 673 F.2d 266, 268 (9th Cir. 1982)). 19 Analysis 20 As explained in detail in the court’s prior screening order, plaintiff brings this action 21 against several individuals and entities involved with her son’s child custody determination. 22 Plaintiff alleges that Placer County CPS misrepresented that they had a warrant when it removed 23 her son from her custody, but that it obtained a warrant the following day. Id. at 2. Plaintiff 24 claims that following her son’s removal, Placer County CPS worker Hilary Trauth and county 25 counselors Kee Ana Smith and Roger Coffman, made misrepresentations about her to the court. 26 Those misrepresentations, plaintiff alleges, ultimately lead to her loss of custody of her son. Id. at 27 2-6. 28 1 As an initial matter, Placer County Superior Court, Judge Nicolas, and county counselors 2 Smith and Coffman, are immune from this suit.1 Placer County Superior Court is an arm of the 3 state and thus cannot be sued in federal court pursuant to the Eleventh Amendment. See Simmons 4 v. Sacramento Cnty. Superior Ct., 318 F.3d 1156,1161 (9th Cir. 2003) (11th Amendment bars suit 5 against state superior court and its employees); Franceschi v. Schwartz, 57 F.3d 828, 831 (9th 6 Cir. 1995) (California municipal court is arm of state protected from lawsuit by 11th Amendment 7 immunity). Plaintiff’s claim against Judge Nicolas is also barred. State judges are absolutely 8 immune from civil liability for damages for acts performed in his or her judicial capacity. 9 Pierson v. Ray, 386 U.S. 547, 553-55 (1967) (applying judicial immunity to actions under 42 10 U.S.C. § 1983). Judicial immunity is an immunity from suit for damages, not just from an 11 ultimate assessment of damages. Mitchell v. Forsyth, 472 U.S. 511, 526 (1985). Finally, county 12 counselors Smith and Coffman, who appear to have been acting as prosecutors, enjoy immunity 13 from suits when they act within the scope of their prosecutorial duties. See Imbler v. Pachtman, 14 424 U.S. 409, 420 (1976). Because plaintiff attempts to impose liability for acts taken in the 15 county counsels’ prosecutorial capacity, these claims fail. 16 The complaint generally alleges that plaintiff’s civil rights were violated during the 17 pendency of the state court custody determination. But those claims violate Rooker-Feldman and 18 are thus barred. Noel v. Hall, 341 F.3d 1148, 1163-65 (9th Cir. 2003) (discussing Rooker- 19 Feldman doctrine); see also Henrichs v. Valley View Dev., 474 F.3d 609, 616 (9th Cir. 2007) 20 (explaining that the Rooker-Feldman doctrine barred the plaintiff’s claim because alleged legal 21 injuries arose from the “state court’s purportedly erroneous judgment” and the relief he sought 22 “would require the district court to determine that the state court’s decision was wrong and thus 23 void”). The Rooker-Feldman doctrine divests federal district courts of jurisdiction to conduct 24 direct reviews of final state court determination. See Worldwide Church of God v. McNair, 805 25 F.2d 888, 890 (9th Cir. 1986) (“The United States District Court . . . has no authority to review 26

27 1 Plaintiff lists in the heading of her complaint several California Welfare and Institutions codes and California Rules of Court. See ECF No. 12 at 1. However, the application of those 28 codes and rules are not explained in the complaint and none create a basis for a cause of action. 1 the final determinations of a state court in judicial proceedings.”). Moreover, plaintiff’s 2 allegation that CPS employee Trauth made false statements to the state court are barred by 3 Rooker-Feldman because plaintiff had the opportunity to present this argument to the state court 4 before the court made its final determination. See Reusser v. Wachovia Bank, N.A., 525 F.3d 855

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386 U.S. 547 (Supreme Court, 1967)
Imbler v. Pachtman
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City of Oklahoma v. Tuttle
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Mitchell v. Forsyth
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Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
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673 F.2d 266 (Second Circuit, 1982)
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Bluebook (online)
(PS) Genessi v. Placer County Superior Court, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-genessi-v-placer-county-superior-court-caed-2024.