Ralstin v. Human Services Administration of Santa Cruz County

CourtDistrict Court, N.D. California
DecidedFebruary 23, 2022
Docket3:21-cv-07845
StatusUnknown

This text of Ralstin v. Human Services Administration of Santa Cruz County (Ralstin v. Human Services Administration of Santa Cruz County) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ralstin v. Human Services Administration of Santa Cruz County, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RYAN MARTIN RALSTIN, Case No. 21-cv-07845-WHO (PR)

Plaintiff, 8 ORDER OF DISMISSAL v. 9

10 HUMAN SERVICES ADMINISTRATION OF SANTA 11 CRUZ COUNTY, et al., Defendants. 12

13 INTRODUCTION 14 Plaintiff Ryan Martin Ralstin brings suit against a social worker for allegedly 15 testifying falsely at a 2020 state court proceeding. His 42 U.S.C. § 1983 complaint 16 containing these allegations is now before the Court for review pursuant to 28 U.S.C. 17 § 1915A(a). 18 This action will be dismissed because the main defendant is protected by witness 19 immunity; Ralstin has failed to state any claim for relief against the remaining defendants 20 and he has not specified which constitutional rights were violated by any defendant; and 21 plaintiff’s suit is barred by Supreme Court precedent. 22 STANDARD OF REVIEW 23 A federal court must conduct a preliminary screening in any case in which a 24 prisoner seeks redress from a governmental entity or officer or employee of a 25 governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any 26 cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim 27 upon which relief may be granted or seek monetary relief from a defendant who is immune 1 from such relief. See id. § 1915A(b)(1), (2). Pro se pleadings must be liberally construed. 2 See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 3 A “complaint must contain sufficient factual matter, accepted as true, to ‘state a 4 claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) 5 (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial 6 plausibility when the plaintiff pleads factual content that allows the court to draw the 7 reasonable inference that the defendant is liable for the misconduct alleged.” Id. (quoting 8 Twombly, 550 U.S. at 556). Furthermore, a court “is not required to accept legal 9 conclusions cast in the form of factual allegations if those conclusions cannot reasonably 10 be drawn from the facts alleged.” Clegg v. Cult Awareness Network, 18 F.3d 752, 754-55 11 (9th Cir. 1994). 12 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 13 elements: (1) that a right secured by the Constitution or laws of the United States was 14 violated, and (2) that the alleged violation was committed by a person acting under the 15 color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). 16 DISCUSSION 17 Ralstin alleges that because a social worker, Anna Lubin, testified falsely in a state 18 court proceeding in 2020, he was arrested and lost the custody of his son. (Am. Compl., 19 Dkt. No. 8 at 3.) He also names as defendants the Human Services Administration of 20 Santa Cruz County and Mary Bergman, another social worker. But for the reasons below, 21 no claim has merit. 22 First, Lubin is immune from suit even if she testified falsely. A witness is 23 absolutely immune from liability for testimony in earlier state or federal court proceedings 24 even if he or she committed perjury. See Briscoe v. LaHue, 460 U.S. 325, 329-46 (1983) 25 (police officer witness at trial); Holt v. Castaneda, 832 F.2d 123, 127 (9th Cir. 1987) 26 (police officer witness at probable cause hearing), cert. denied, 485 U.S. 979 (1988); Burns 27 v. County of King, 883 F.2d 819 (9th Cir. 1989) (social worker preparing affidavit for use 1 Second, Ralstin has not alleged claims against the remaining defendants, nor has he 2 || stated which specific constitutional rights were violated by any defendant. Allowing 3 amendment would be futile; there is no plausible link between the remaining defendants 4 || and the incidents described in the complaint. 5 Third, because Ralstin was convicted, his section 1983 suit is barred by Heck v. 6 || Humphrey, 512 U.S. 477 (1994). Heck bars section 1983 actions for damages for an 7 || allegedly unconstitutional conviction or imprisonment or for other harm caused by actions 8 || whose unlawfulness would render a conviction or sentence invalid. Jd. at 486-487. When 9 || state prisoner seeks damages in a section 1983 suit, the district court must therefore 10 || consider whether a judgment in favor of the plaintiff would necessarily imply the 11 || invalidity of his conviction or sentence; if it would, the complaint must be dismissed 2 unless the plaintiff can demonstrate that the conviction or sentence has already been 5 13 || invalidated. Jd. at 487. The Heck bar applies here because a judgment that defendants S 14 || violated his constitutional rights would necessarily imply the invalidity of his convictions 3 15 || and sentence. The Heck bar can be avoided if a plaintiff can prove that the conviction or a 16 || sentence has been reversed on direct appeal, expunged by executive order, declared invalid

17 || by astate tribunal authorized to make such determination, or called into question by a 18 || federal court’s issuance of a writ of habeas corpus. /d. Ralstin has made no showing (or 19 || even alleged) that Heck does not bar his case. 20 For all these reasons, the suit will be dismissed. 21 CONCLUSION 22 This federal civil rights action is DISMISSED. The Clerk shall enter judgment in 23 favor of defendants, and close the file. 24 IT IS SO ORDERED. 25 || Dated: February 23, 2022 . \f C0 ® *6 WM 27 United States District Judge 28

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Related

Briscoe v. LaHue
460 U.S. 325 (Supreme Court, 1983)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Chauncey Marvin Holt v. Richard Modesto Castaneda
832 F.2d 123 (Ninth Circuit, 1987)
Burns v. County of King
883 F.2d 819 (Ninth Circuit, 1989)

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Ralstin v. Human Services Administration of Santa Cruz County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ralstin-v-human-services-administration-of-santa-cruz-county-cand-2022.