(PS) Olson v. Law Office of Joseph M. Ahart, Inc.

CourtDistrict Court, E.D. California
DecidedMarch 24, 2025
Docket2:25-cv-00876
StatusUnknown

This text of (PS) Olson v. Law Office of Joseph M. Ahart, Inc. ((PS) Olson v. Law Office of Joseph M. Ahart, 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) Olson v. Law Office of Joseph M. Ahart, Inc., (E.D. Cal. 2025).

Opinion

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6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 KIMBERLY R. OLSON, No. 2:25-cv-00876 DJC AC PS 12 Plaintiff, 13 v. ORDER and 14 LAW OFFICES OF JOSEPH M. AHART, FINDINGS AND RECOMMENDATIONS INC., JOSEPH M. AHART, AND JACOB 15 LEVIN, 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 has submitted the affidavit required by that statute. See 28 U.S.C. 21 § 1915(a)(1). The motion to proceed IFP (ECF No. 2) will therefore be granted. 22 I. Screening 23 The federal IFP statute requires federal courts to dismiss a case if the action is legally 24 “frivolous or malicious,” fails to state a claim upon which relief may be granted or seeks 25 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2). A 26 claim is legally frivolous when it lacks an arguable basis either in law or in fact. Neitzke v. 27 Williams, 490 U.S. 319, 325 (1989). In reviewing a complaint under this standard, the court will 28 1 (1) accept as true all of the factual allegations contained in the complaint, unless they are clearly 2 baseless or fanciful, (2) construe those allegations in the light most favorable to the plaintiff, and 3 (3) resolve all doubts in the plaintiff’s favor. See Neitzke, 490 U.S. at 327; Von Saher v. Norton 4 Simon Museum of Art at Pasadena, 592 F.3d 954, 960 (9th Cir. 2010), cert. denied, 564 U.S. 5 1037 (2011). 6 The court applies the same rules of construction in determining whether the complaint 7 states a claim on which relief can be granted. Erickson v. Pardus, 551 U.S. 89, 94 (2007) (court 8 must accept the allegations as true); Scheuer v. Rhodes, 416 U.S. 232, 236 (1974) (court must 9 construe the complaint in the light most favorable to the plaintiff). Pro se pleadings are held to a 10 less stringent standard than those drafted by lawyers. Haines v. Kerner, 404 U.S. 519, 520 11 (1972). However, the court need not accept as true conclusory allegations, unreasonable 12 inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 618, 13 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does not suffice 14 to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); Ashcroft v. Iqbal, 15 556 U.S. 662, 678 (2009). 16 To state a claim on which relief may be granted, the plaintiff must allege enough facts “to 17 state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has 18 facial plausibility when the plaintiff pleads factual content that allows the court to draw the 19 reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 20 678. A pro se litigant is entitled to notice of the deficiencies in the complaint and an opportunity 21 to amend, unless the complaint’s deficiencies could not be cured by amendment. See Noll v. 22 Carlson, 809 F.2d 1446, 1448 (9th Cir. 1987), superseded on other grounds by statute as stated in 23 Lopez v. Smith, 203 F.3d 1122 (9th Cir.2000)) (en banc). 24 A. The Complaint 25 Plaintiff is an indigent criminal defendant in Siskiyou County, and attorneys Joseph M. 26 Ahart and Jacob Levin were appointed to represent her. ECF No. 1 at 1. Plaintiff alleges both 27 attorneys are employees of the Law Office of Joseph M. Ahart, Inc., which has a contract to 28 provide conflict counsel to criminal defendants in Siskiyou County. Id. at 2. Plaintiff alleges that 1 counsel violated their contractual obligations to her by providing inadequate representation. Id. at 2 3-4. Plaintiff also alleges defendants are liable under 42 U.S.C. § 1983 for violating her 3 constitutional rights. Specifically, plaintiff argues that counsel did not meaningfully collaborate 4 with her, refusing to consider her “crucial defense evidence and strategies.” Id. at 6. Plaintiff 5 brings three causes of action: (1) Deprivation of Right to Effective Assistance of Counsel (Sixth 6 and Fourteenth Amendments) under 42 U.S.C. §1983; (2) Deprivation of Fourteenth Amendment 7 Due Process and Equal Protection Rights under §1983; and (3) Breach of Contract (Third-Party 8 Beneficiary Liability). ECF No. 1 at 10-16. 9 B. Analysis 10 This complaint must be dismissed because it does not state any claims upon which relief 11 can be granted. First, public defenders and other appointed indigent defense counsel cannot be 12 sued under § 1983. Although the protection afforded to public defenders is not an immunity, it is 13 well-established that a public defender is not a person who acts “under color of law” within the 14 meaning of § 1983. Polk County v. Dodson, 454 U.S. 312, 325 (1981). When a public defender 15 is “performing a lawyer’s traditional functions as counsel to a defendant in a criminal 16 proceeding,” a § 1983 claim does not lie. Id. Here, plaintiff alleges ineffective assistance of 17 counsel and breach of due process under § 1983 against her appointed defense counsel. It is clear 18 from the allegations that her complaint is entirely based in counsel’s alleged failures to properly 19 handle plaintiff’s defense, particularly by failing to properly communicate with her and failing to 20 consider her views on legal strategy and the presentation of evidence. Such allegations cannot 21 support a claim for damages under § 1983 as a matter of law. Additionally, the court notes that 22 potential claims for legal malpractice do not come within the jurisdiction of the federal courts. 23 Franklin v. Oregon, 662 F.2d 1337, 1344 (9th Cir. 1981). 24 Plaintiff’s remaining claim for breach of contract is a state law claim. Because the only 25 two federal causes of action asserted by plaintiff are not cognizable, the court will not entertain 26 the state law claim. “Federal courts are courts of limited jurisdiction.” Kokkonen v. Guardian 27 Life Ins. Co. of Am., 511 U.S. 375, 377, (1994). In 28 U.S.C. §§ 1331 and 1332(a), “Congress 28 granted federal courts jurisdiction over two general types of cases: cases that “aris[e] under” 1 federal law, § 1331, and cases in which the amount in controversy exceeds $ 75,000 and there is 2 diversity of citizenship among the parties, § 1332(a).

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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)
Polk County v. Dodson
454 U.S. 312 (Supreme Court, 1981)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
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)
Von Saher v. Norton Simon Museum of Art at Pasadena
592 F.3d 954 (Ninth Circuit, 2010)
Turner v. Duncan
158 F.3d 449 (Ninth Circuit, 1998)
Lopez v. Smith
203 F.3d 1122 (Ninth Circuit, 2000)
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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(PS) Olson v. Law Office of Joseph M. Ahart, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-olson-v-law-office-of-joseph-m-ahart-inc-caed-2025.