Quinn v. King County Risk Management

• Court: District Court, W.D. Washington
• Decided: August 25, 2025
• Docket: 2:25-cv-01356
• Status: Unknown

Opinion

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3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 AEDIN QUINN, CASE NO. 2:25-cv-01356-JNW 8 Plaintiff, ORDER TO SHOW CAUSE 9 v. 10 KING COUNTY RISK 11 MANAGEMENT,

12 Defendant. 13 Pro se Plaintiff Aedin Quinn pursues this action against Defendant King 14 County Risk Management (the County) in forma pauperis (IFP). After reviewing the 15 operative complaint, Dkt. No. 5, under 28 U.S.C. § 1915(e)(2)(B), the Court finds 16 that Quinn fails to state a claim on which relief may be granted. Rather than 17 dismissing his case outright, however, the Court grants Quinn leave to amend his 18 complaint within 30 days of this Order to avoid dismissal. 19 When a plaintiff proceeds in forma pauperis, the court must dismiss the 20 action if the court determines the action is frivolous or malicious, fails to state a 21 claim on which relief may be granted, or seeks monetary relief against a defendant 22 who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). When reviewing 23 1 complaints under § 1915(e)(2)(B), courts necessarily consider only the operative 2 complaint. See Valadez-Lopez v. Chertoff, 656 F.3d 851, 857 (9th Cir. 2011) (holding

3 that an amended complaint supersedes the original and renders the original of no 4 legal effect). 5 Under the Federal Rules of Civil Procedure, “[p]leadings must be construed 6 so as to do justice.” Fed. R. Civ. P. 8(e). Thus, a “document filed pro se is to be 7 liberally construed and a pro se complaint, however inartfully pleaded, must be held 8 to less stringent standards than formal pleadings drafted by lawyers.” Erickson v.

9 Pardus, 551 U.S. 89, 94 (2007) (citations omitted). Courts are not to “dismiss a pro 10 se complaint without leave to amend unless ‘it is absolutely clear that the 11 deficiencies of the complaint could not be cured by amendment.’” Rosati v. Igbinoso, 12 791 F.3d 1037, 1039 (9th Cir. 2015) (citing Akhtar v. Mesa, 698 F.3d 1202, 1212 (9th 13 Cir. 2012) (quoting Schucker v. Rockwood, 846 F.2d 1202, 1204 (9th Cir.1988) (per 14 curiam))). But even so, the duties imposed on the Court by § 1915(e) are 15 unwavering, and when an IFP plaintiff fails to state a claim on which relief may be

16 granted, the action must be dismissed. Likewise, the Federal Rules require a 17 complaint to offer: (1) a short and plain statement of the grounds for the court’s 18 jurisdiction; (2) a short and plain statement of the claim showing that the pleader is 19 entitled to relief; and (3) a demand for the relief sought. Fed. R. Civ. P. 8. 20 Quinn alleges that he was employed as a bus driver for King County Metro 21 and suffered a severe spinal injury while on the job in July 2017. Dkt. 5 at 3. He

22 asserts that he applied for disability benefits with the state agency, and “[t]he 23 agency denied benefits in an order dated July 7, 2023, without rebuttal of [his 1 medical expert’s] testimony.” Id. Quinn asks the Court to “examine the 2 [administrative] record” to determine whether the state agency erred.

3 For his first cause of action, he asserts a violation of procedural due process, 4 alleging he was “denied a fair hearing when the burden of proof was silently shifted 5 to him without notice, depriving him of the opportunity to respond or present 6 rebuttal.” Id. at 6. He explains that “during proceedings, [he] attempted to clarify 7 whether Defendants had reviewed [his proffered] medical reports[.]” Dkt. No. 5 at 4. 8 He alleges that the judge interrupted him, preventing his “clarification from

9 entering the record.” Id. Quinn explains, “[t]his interruption deprived [him] of a 10 meaningful opportunity to be heard on a material issue and concealed the 11 structural due process error that followed: a judgment rendered without addressing 12 unrebutted expert evidence[.]” Id. He also asserts that his complaint raises 13 “structural due process violations stemming from the trial court’s silent shifting of 14 the burden of proof and the absence of any rebuttal to Plaintiff’s expert testimony.” 15 Id. at 1.

16 His second claim is listed as “Unconstitutional Denial of Earned Benefits,” for 17 which he alleges “[t]he denial of benefits violated Plaintiff’s protected property 18 interest in earned disability compensation, constituting an unlawful taking under 19 color of state law without due process.” Id. 20 The Court finds that the operative complaint, Dkt. No. 5, fails to state a claim 21 upon which relief can be granted. See 28 U.S.C. § 1915(e)(2)(B). “To show a

22 procedural due process violation, a plaintiff must prove two distinct elements: ‘(1) a 23 deprivation of a constitutionally protected liberty or property interest, and (2) a 1 denial of adequate procedural protections.” United States v. 101 Houseco, LLC, 22 2 F.4th 843, 851 (9th Cir. 2022) (quoting Brewster v. Bd. of Educ. of Lynwood Unified

3 Sch. Dist., 149 F.3d 971, 982 (9th Cir. 1998)). 4 Taken as true, Quinn’s allegations show that the judge presiding over a 5 hearing regarding disability benefits interrupted him, then issued a decision with 6 which he disagrees. But Quinn fails to plausibly allege either element of a due 7 process violation. First, he does not adequately plead that he had a protected 8 property interest in the disability benefits he sought. Second, his allegations about

9 being interrupted during a hearing do not plausibly suggest a denial of adequate 10 procedural protections. When allegations are “in line with a wide swath of rational” 11 and legal behavior, they do not plausibly allege violations of the law. Bell Atl. Corp. 12 v. Twombly, 550 U.S. 544, at 557 (2007) (“The need at the pleading stage for 13 allegations plausibly suggesting (not merely consistent with) agreement reflects the 14 threshold requirement of Rule 8(a)(2) that the ‘plain statement’ possess enough heft 15 to ‘sho[w] that the pleader is entitled to relief.’”).

16 Accordingly, the Court ORDERS: 17 • To avoid dismissal of this action, Quinn may file an amended 18 complaint that states a claim on which relief may be granted WITHIN 19 21 DAYS of the date of this Order. Failure to do so by the deadline will 20 result in dismissal of this action under 28 U.S.C. § 1915(e)(2)(B), 21 without prejudice.

22 • If filed, the amended complaint will serve as a complete substitute for 23 the current complaint. Thus, any amended complaint must not 1 incorporate the original complaint by reference, nor may it incorporate 9 by reference any complaints from other litigation. Any amended

3 complaint must clearly identify the claims and the facts that support 4 each claim.

5 G Dated this 25th day of August, 2025.

‘ pease — 8 amal N. Whitehead United States District Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23