Redin v. St. Joseph Hospital Eureka

CourtDistrict Court, N.D. California
DecidedJune 29, 2022
Docket5:22-cv-00776
StatusUnknown

This text of Redin v. St. Joseph Hospital Eureka (Redin v. St. Joseph Hospital Eureka) 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
Redin v. St. Joseph Hospital Eureka, (N.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 CHRISTOPHER REDIN, 11 Case No. 22-cv-00776 BLF (PR) Plaintiff, 12 ORDER OF DISMISSAL WITH LEAVE TO AMEND v. 13

14 HUMBOLDT COUNTY SUPERIOR 15 COURT, et al.,

16 Defendants.

17 18 Plaintiff, who appears to be a pretrial detainee currently confined at the Humboldt 19 County Correctional Facility, filed the instant pro se civil rights action pursuant to 42 20 U.S.C. § 1983, against various Defendants in Humboldt County.1 Dkt. No. 1 at 4. 21 Plaintiff’s motion for leave to proceed in forma pauperis will be addressed in a separate 22 order. 23 DISCUSSION 24 A. Standard of Review 25 A federal court must conduct a preliminary screening in any case in which a 26 prisoner seeks redress from a governmental entity or officer or employee of a 27 1 governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any 2 cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim 3 upon which relief may be granted or seek monetary relief from a defendant who is immune 4 from such relief. See id. § 1915A(b)(1),(2). Pro se pleadings must, however, be liberally 5 construed. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 6 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 7 elements: (1) that a right secured by the Constitution or laws of the United States was 8 violated, and (2) that the alleged violation was committed by a person acting under the 9 color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). 10 B. Plaintiff’s Claims 11 Plaintiff names the following as defendants in this action: (1) St. Joseph’s Hospital 12 in Eureka, California; (2) Eureka Police Department; (3) Officer Leonard La France; (4) 13 Humboldt County District Attorney’s Office; (5) Maggie Fleming (D.A.); (6) Capt. 14 Christian of the Humboldt County Jail; and (7) Arcata Police Department. Dkt. No. 1 at 2. 15 In the complaint’s “statement of claim,” Plaintiff asserts that the Humboldt County 16 District Attorney’s office has engaged in misconduct, including “cover-ups, over-charging, 17 malicious abuse of process, faulty investigations and pre-trial tactics, and illegitimate 18 extraditions.” Id. Plaintiff refers to a withdrawn plea in 2017, and new charges being filed 19 in 2020. Id. at 3. Plaintiff also claims that the Eureka Police Department made two 20 warrantless arrests, and that the Arcata Police Department made a false arrest and were 21 negligent in 2019. Id. Plaintiff claims that St. Joseph’s Hospital falsely reported a fracture 22 as bruise. Id. Lastly, Plaintiff claims that he was harassed while in custody, including 23 unreasonable strip search and interference with legal counsel visitation. Id. As relief, 24 Plaintiff seeks “federal oversight on current charges/matters, review of my commitments, 25 cases, conditions of custody as well as malicious prosecution tactics employed against me 26 for several years; expunged record restoring my citizen (and employment) status, 1 allegations, it appears that there may be ongoing state criminal proceedings against 2 Plaintiff. 3 Under principles of comity and federalism, a federal court should not interfere with 4 ongoing state criminal proceedings by granting injunctive or declaratory relief absent 5 extraordinary circumstances. See Younger v. Harris, 401 U.S. 37, 43-46 (1971); Samuels 6 v. Mackell, 401 U.S. 66, 68-74 (1971). Younger abstention is required when: (1) state 7 proceedings, judicial in nature, are pending; (2) the state proceedings involve important 8 state interests; and (3) the state proceedings afford adequate opportunity to raise the 9 constitutional issue. See Middlesex County Ethics Comm. v. Garden State Bar Ass’n, 457 10 U.S. 423, 432 (1982). All three elements must be present. Agriesti v. MGM Grand Hotels, 11 Inc., 53 F.3d 1000, 1001 (9th Cir. 1995) (abstention improper where arrest and issuance of 12 citation were executive acts not judicial in nature, and only potential for future state 13 judicial proceedings existed). A fourth requirement has also been articulated by the Ninth 14 Circuit: that “the federal court action would enjoin the state proceeding or have the 15 practical effect of doing so, i.e., would interfere with the state proceeding in a way that 16 Younger disapproves.” SJSVCCPAC v. City of San Jose, 546 F.3d 1087, 1092 (9th Cir. 17 2008) (citing cases). 18 There is insufficient information in the complaint for the Court to determine 19 whether Plaintiff is a pretrial detainee with criminal proceedings pending against him or a 20 convicted felon serving a sentence. If the former, Younger abstention may apply. Plaintiff 21 shall be granted leave to amend to allege sufficient facts for the Court to make this 22 determination. He is advised that if there are ongoing criminal proceedings against him, he 23 must show that extraordinary circumstances warrant federal intervention to overcome 24 Younger abstention. 25 On the other hand, if Plaintiff has been convicted and is challenging the 26 constitutionality of his conviction and sentence, a § 1983 action is not the appropriate 1 may be challenged in federal habeas corpus once state remedies have been exhausted. See 2 Nelson v. Sandritter, 351 F.2d 284, 285 (9th Cir. 1965). Furthermore, although a district 3 court may construe a habeas petition by a prisoner attacking the conditions of his 4 confinement as a civil rights action under 42 U.S.C. § 1983, see Wilwording v. Swenson, 5 404 U.S. 249, 251 (1971), the opposite is not true: A civil rights complaint seeking habeas 6 relief should be dismissed without prejudice to bringing it as a petition for writ of habeas 7 corpus. See Trimble v. City of Santa Rosa, 49 F.3d 583, 586 (9th Cir. 1995). Accordingly, 8 if Plaintiff is seeking to challenge his state conviction and sentence, this action should be 9 dismissed without prejudice to his refiling as a petition for habeas corpus pursuant to 28 10 U.S.C. § 2254. He must make his status clear in an amended complaint. 11 Furthermore, if Plaintiff is seeking damages for the wrongful conviction, he must 12 prove that the conviction or sentence has been reversed on direct appeal, expunged by 13 executive order, declared invalid by a state tribunal authorized to make such determination, 14 or called into question by a federal court's issuance of a writ of habeas corpus. Heck v. 15 Humphrey, 512 U.S. 477

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Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
WILWORDING Et Al. v. SWENSON, WARDEN
404 U.S. 249 (Supreme Court, 1971)
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West v. Atkins
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Redin v. St. Joseph Hospital Eureka, Counsel Stack Legal Research, https://law.counselstack.com/opinion/redin-v-st-joseph-hospital-eureka-cand-2022.