(PS) Holt v. Nor Cal Towing and Transport, Inc.

CourtDistrict Court, E.D. California
DecidedJune 3, 2025
Docket2:25-cv-00306
StatusUnknown

This text of (PS) Holt v. Nor Cal Towing and Transport, Inc. ((PS) Holt v. Nor Cal Towing and Transport, Inc.) 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) Holt v. Nor Cal Towing and Transport, Inc., (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 SANDY HOLT, Case No. 2:25-cv-00306-DC-CSK PS 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 NOR CAL TOWING AND (ECF Nos. 1, 2) TRANSPORT, INC., 15 Defendant. 16

17 18 Plaintiff Sandy Holt is representing herself in this action and seeks leave to 19 proceed in forma pauperis (“IFP”) pursuant to 28 U.S.C. § 1915.1 (ECF No. 2.) For the 20 reasons that follow, the Court recommends Plaintiff’s IFP application be denied, and the 21 Complaint be dismissed without leave to amend. 22 I. MOTION TO PROCEED IN FORMA PAUPERIS 23 28 U.S.C. § 1915(a) provides that the court may authorize the commencement, 24 prosecution or defense of any suit without prepayment of fees or security “by a person 25 who submits an affidavit stating the person is “unable to pay such fees or give security 26 therefor.” This affidavit is to include, among other things, a statement of all assets the 27 1 This matter proceeds before the undersigned pursuant to 28 U.S.C. § 636, Fed. R. 28 Civ. P. 72, and Local Rule 302(c). 1 person possesses. Id. The IFP statute does not itself define what constitutes insufficient 2 assets. See Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015). In Escobedo, 3 the Ninth Circuit stated that an affidavit in support of an IFP application is sufficient 4 where it alleges that the affiant cannot pay court costs and still afford the necessities of 5 life. Id. “One need not be absolutely destitute to obtain benefits of the in forma pauperis 6 statute.” Id. Nonetheless, a party seeking IFP status must allege poverty “with some 7 particularity, definiteness and certainty.” Id. According to the United States Department 8 of Health and Human Services, the current poverty guideline for a household of one (not 9 residing in Alaska or Hawaii) is $15,060.00. See U.S. Dpt. Health & Human Service 10 (available at https://aspe.hhs.gov/poverty-guidelines). 11 Here, Plaintiff’s IFP shows that she has a monthly income of $100. See ECF No. 12 2. Plaintiff has made the required showing under 28 U.S.C. § 1915(a). See id. However, 13 the Court will recommend Plaintiff’s IFP application be denied because the action is 14 facially frivolous and without merit because it fails to state a claim and lacks subject 15 matter jurisdiction. “‘A district court may deny leave to proceed in forma pauperis at the 16 outset if it appears from the face of the proposed complaint that the action is frivolous or 17 without merit.’” Minetti v. Port of Seattle, 152 F.3d 1113, 1115 (9th Cir. 1998) (quoting 18 Tripati v. First Nat. Bank & Tr., 821 F.2d 1368, 1370 (9th Cir. 1987)); see also McGee v. 19 Dep’t of Child Support Servs., 584 Fed. App’x. 638 (9th Cir. 2014) (“the district court did 20 not abuse its discretion by denying McGee's request to proceed IFP because it appears 21 from the face of the amended complaint that McGee's action is frivolous or without 22 merit”); Smart v. Heinze, 347 F.2d 114, 116 (9th Cir. 1965) (“It is the duty of the District 23 Court to examine any application for leave to proceed in forma pauperis to determine 24 whether the proposed proceeding has merit and if it appears that the proceeding is 25 without merit, the court is bound to deny a motion seeking leave to proceed in forma 26 pauperis.”). Because it appears from the face of the Complaint that this action is frivolous 27 and is without merit as discussed in more detail below, the Court recommends denying 28 Plaintiff’s IFP motion. 1 II. SCREENING REQUIREMENT 2 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 3 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to 4 state a claim on which relief may be granted,” or “seeks monetary relief against a 5 defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 6 203 F.3d 1122, 1126-27 (2000) (en banc). A claim is legally frivolous when it lacks an 7 arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). In 8 reviewing a complaint under this standard, the court accepts as true the factual 9 allegations contained in the complaint, unless they are clearly baseless or fanciful, and 10 construes those allegations in the light most favorable to the plaintiff. See Neitzke, 490 11 U.S. at 327; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960 12 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011). 13 Pleadings by self-represented litigants are liberally construed. Hebbe v. Pliler, 627 14 F.3d 338, 342 & n.7 (9th Cir. 2010) (liberal construction appropriate even post–Iqbal). 15 However, the court need not accept as true conclusory allegations, unreasonable 16 inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 17 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does 18 not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); 19 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 20 To state a claim on which relief may be granted, the plaintiff must allege enough 21 facts “to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A 22 claim has facial plausibility when the plaintiff pleads factual content that allows the court 23 to draw the reasonable inference that the defendant is liable for the misconduct alleged.” 24 Iqbal, 556 U.S. at 678. A pro se litigant is entitled to notice of the deficiencies in the 25 complaint and an opportunity to amend unless the complaint’s deficiencies could not be 26 cured by amendment. See Lopez, 203 F.3d at 1130-31; Cahill v. Liberty Mut. Ins. Co., 80 27 F.3d 336, 339 (9th Cir. 1996). 28 / / / 1 III. THE COMPLAINT 2 Plaintiff brings her Complaint against Defendant Nor Cal Towing and Transport, 3 Inc. Compl. at 1 (ECF No. 1). Plaintiff also states that “Defendants are currently 4 employed at Nor Cal Towing and Transport, Inc.,” but Plaintiff does not name any other 5 defendants in the Complaint. Id. ¶¶ 4, 5. Plaintiff alleges that on December 23, 2023, her 6 vehicle was unlawfully towed by Defendant from private property at the direction of two 7 Sacramento County Sheriff deputies. Id. ¶ 6. She states that she arrived at the location 8 before the car was removed and said she would move the car, but her request was 9 ignored. Id. Plaintiff brings four claims under 42 U.S.C. § 1983 for violation of the Fourth, 10 Eighth, and Fourteenth Amendments. Id. ¶¶ 10-17. Plaintiff seeks damages and 11 immediate release of her car. Id. ¶¶ 18-23.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Gomez v. Toledo
446 U.S. 635 (Supreme Court, 1980)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Lanier Professional Services, Inc. v. Ricci
192 F.3d 1 (First Circuit, 1999)
Gu v. Boston Police Department
312 F.3d 6 (First Circuit, 2002)
Wilson v. Moulison North Corp.
639 F.3d 1 (First Circuit, 2011)
Anant Kumar Tripati v. First National Bank & Trust
821 F.2d 1368 (First Circuit, 1987)
Mchenry v. Renne
84 F.3d 1172 (Ninth Circuit, 1996)
Naoko Ohno v. Yuko Yasuma
723 F.3d 984 (Ninth Circuit, 2013)
Von Saher v. Norton Simon Museum of Art at Pasadena
592 F.3d 954 (Ninth Circuit, 2010)
Maria Escobedo v. Apple American Group
787 F.3d 1226 (Ninth Circuit, 2015)
Beil v. Lakewood Engineering & Manufacturing Co.
15 F.3d 546 (Sixth Circuit, 1994)
Cato v. United States
70 F.3d 1103 (Ninth Circuit, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
(PS) Holt v. Nor Cal Towing and Transport, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-holt-v-nor-cal-towing-and-transport-inc-caed-2025.