(PS) Sandford v. Sacramento Police Dept.

CourtDistrict Court, E.D. California
DecidedJune 2, 2025
Docket2:25-cv-00106
StatusUnknown

This text of (PS) Sandford v. Sacramento Police Dept. ((PS) Sandford v. Sacramento Police Dept.) 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) Sandford v. Sacramento Police Dept., (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 JAMES SANDFORD, Case No. 2:25-cv-00106-DJC-CSK PS 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 SACRAMENTO POLICE DEPT., et al., (ECF Nos. 1, 2) 15 Defendants. 16 17 Plaintiff James Sandford is representing himself in this action and seeks leave to 18 proceed in forma pauperis (“IFP”) pursuant to 28 U.S.C. § 1915.1 (ECF No. 2.) For the 19 reasons that follow, the Court recommends Plaintiff’s IFP application be denied, and the 20 Complaint be dismissed without leave to amend. 21 I. MOTION TO PROCEED IN FORMA PAUPERIS 22 28 U.S.C. § 1915(a) provides that the court may authorize the commencement, 23 prosecution or defense of any suit without prepayment of fees or security “by a person 24 who submits an affidavit stating the person is “unable to pay such fees or give security 25 therefor.” This affidavit is to include, among other things, a statement of all assets the 26 person possesses. Id. The IFP statute does not itself define what constitutes insufficient 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 assets. See Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015). In Escobedo, 2 the Ninth Circuit stated that an affidavit in support of an IFP application is sufficient 3 where it alleges that the affiant cannot pay court costs and still afford the necessities of 4 life. Id. “One need not be absolutely destitute to obtain benefits of the in forma pauperis 5 statute.” Id. Nonetheless, a party seeking IFP status must allege poverty “with some 6 particularity, definiteness and certainty.” Id. According to the United States Department 7 of Health and Human Services, the current poverty guideline for a household of one (not 8 residing in Alaska or Hawaii) is $15,060.00 and $21,150 for a household of two. See 9 U.S. Dpt. Health & Human Service (available at https://aspe.hhs.gov/poverty-guidelines). 10 Here, Plaintiff’s IFP application appears incomplete. Plaintiff’s IFP shows that his 11 “gross pay or wages are” $1,900 but does not indicate how often he receives this 12 amount. See ECF No. 2. Assuming this is $1,900 per month, this totals $22,800 a year. 13 Plaintiff also lists one dependent. Id. Plaintiff has likely made the required showing under 14 28 U.S.C. § 1915(a). See id. However, the Court will recommend Plaintiff’s IFP 15 application be denied because the action is without merit because it is barred by the 16 statute of limitations and fails to state a claim. “‘A district court may deny leave to 17 proceed in forma pauperis at the outset if it appears from the face of the proposed 18 complaint that the action is frivolous or without merit.’” Minetti v. Port of Seattle, 152 F.3d 19 1113, 1115 (9th Cir. 1998) (quoting Tripati v. First Nat. Bank & Tr., 821 F.2d 1368, 1370 20 (9th Cir. 1987)); see also McGee v. Dep’t of Child Support Servs., 584 Fed. App’x 638 21 (9th Cir. 2014) (“the district court did not abuse its discretion by denying McGee's 22 request to proceed IFP because it appears from the face of the amended complaint that 23 McGee's action is frivolous or without merit”); Smart v. Heinze, 347 F.2d 114, 116 (9th 24 Cir. 1965) (“It is the duty of the District Court to examine any application for leave to 25 proceed in forma pauperis to determine whether the proposed proceeding has merit and 26 if it appears that the proceeding is without merit, the court is bound to deny a motion 27 seeking leave to proceed in forma pauperis.”). Because it appears from the face of the 28 Complaint that this action is without merit as discussed in more detail below, the Court 1 recommends denying Plaintiff’s IFP motion. 2 II. SCREENING REQUIREMENT 3 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 4 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to 5 state a claim on which relief may be granted,” or “seeks monetary relief against a 6 defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 7 203 F.3d 1122, 1126-27 (2000) (en banc). A claim is legally frivolous when it lacks an 8 arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989). In 9 reviewing a complaint under this standard, the court accepts as true the factual 10 allegations contained in the complaint, unless they are clearly baseless or fanciful, and 11 construes those allegations in the light most favorable to the plaintiff. See Neitzke, 490 12 U.S. at 327; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 954, 960 13 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011). 14 Pleadings by self-represented litigants are liberally construed. Hebbe v. Pliler, 627 15 F.3d 338, 342 & n.7 (9th Cir. 2010) (liberal construction appropriate even post-Iqbal). 16 However, the court need not accept as true conclusory allegations, unreasonable 17 inferences, or unwarranted deductions of fact. Western Mining Council v. Watt, 643 F.2d 18 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of action does 19 not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 (2007); 20 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 21 To state a claim on which relief may be granted, the plaintiff must allege enough 22 facts “to state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A 23 claim has facial plausibility when the plaintiff pleads factual content that allows the court 24 to draw the reasonable inference that the defendant is liable for the misconduct alleged.” 25 Iqbal, 556 U.S. at 678. A pro se litigant is entitled to notice of the deficiencies in the 26 complaint and an opportunity to amend unless the complaint’s deficiencies could not be 27 cured by amendment. See Lopez, 203 F.3d at 1130-31; Cahill v. Liberty Mut. Ins. Co., 80 28 F.3d 336, 339 (9th Cir. 1996). 1 III. THE COMPLAINT 2 Plaintiff filed his Complaint against the Sacramento Police Department, Police 3 Officer Brandon Mullock, and the City of Sacramento. Compl. at 1 (ECF No. 1). Plaintiff’s 4 allegations appear to be specifically against Defendant Mullock only. Plaintiff alleges that 5 in March 2009, Defendant Mullock submitted a police report that contained false 6 information. Id. Plaintiff brings a claim for unlawful search and seizure under the Fourth 7 Amendment because he was allegedly subjected to a full strip search while in custody. 8 Id. Plaintiff also brings a claim for “denial of a fair trial” under the Sixth Amendment. Id.

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(PS) Sandford v. Sacramento Police Dept., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-sandford-v-sacramento-police-dept-caed-2025.