Tingle v. State of California

CourtDistrict Court, N.D. California
DecidedJune 17, 2024
Docket4:24-cv-00929
StatusUnknown

This text of Tingle v. State of California (Tingle v. State of California) 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
Tingle v. State of California, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 AARON KRISTOPHER TINGLE, Case No. 24-cv-00929-HSG

8 Plaintiff, ORDER OF DISMISSAL WITH LEAVE TO AMEND 9 v.

10 STATE OF CALIFORNIA, et al., 11 Defendants.

12 13 Plaintiff, a prisoner housed at Alameda County Jail, has filed a pro se action pursuant to 42 14 U.S.C. § 1983. His complaint (Dkt. No. 1) is now before the Court for review under 28 U.S.C. § 15 1915A. Plaintiff has been granted leave to proceed in forma pauperis in a separate order. 16 DISCUSSION 17 A. Standard of Review 18 A federal court must conduct a preliminary screening in any case in which a prisoner seeks 19 redress from a governmental entity or officer or employee of a governmental entity. See 28 U.S.C. 20 § 1915A(a). In its review, the court must identify any cognizable claims and dismiss any claims 21 that are frivolous, malicious, fail to state a claim upon which relief may be granted or seek 22 monetary relief from a defendant who is immune from such relief. See 28 U.S.C. § 1915A(b)(1), 23 (2). Pro se pleadings must, however, be liberally construed. See United States v. Qazi, 975 F.3d 24 989, 993 (9th Cir. 2020). 25 Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the 26 claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “Specific facts are not 27 necessary; the statement need only “‘give the defendant fair notice of what the . . . claim is and the 1 While Rule 8 does not require detailed factual allegations, it demands more than an unadorned, 2 the-defendant-unlawfully-harmed-me accusation. Ashcroft v. Iqbal, 556 U.S. 662, 677–78 (2009). 3 A pleading that offers only labels and conclusions, or a formulaic recitation of the elements of a 4 cause of action, or naked assertions devoid of further factual enhancement does not suffice. Id. 5 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential elements: (1) that a 6 right secured by the Constitution or laws of the United States was violated, and (2) that the alleged 7 violation was committed by a person acting under the color of state law. See West v. Atkins, 487 8 U.S. 42, 48 (1988). 9 B. Complaint 10 Plaintiff names as defendants the State of California; former Alameda County District 11 Attorney Nancy O’Malley; Alameda County public defender Brendon D. Woods; Oakland Police 12 Department (“OPD”) officers Sarah Hicks and Caesar Basa and detective McClain; former 13 Alameda County Deputy District Attorney Amilcar Ford; and Alameda County Jail – Santa Rita. 14 The complaint alleges the following. The State of California has employed various 15 persons in the criminal justice system that have violated Plaintiff’s rights. Defendant former 16 Alameda County District Attorney O’Malley employed and enable a group of police officers and 17 attorneys to fraudulently prosecute Plaintiff in 2005, and employed a known gang called “The 18 Riders,” some of whom have been federally prosecuted. Defendant Alameda County public 19 defender Brendon D. Woods and members of the Alameda County Public Defender’s Office 20 violated Plaintiff’s rights by incompetently representing him in 2015 to 2016 despite having a 21 conflict of interest, due to their simultaneous representation of others who were a part of Plaintiff’s 22 case and were witnesses for the District Attorney’s Office. Defendant OPD officer Hicks violated 23 Plaintiff’s rights when she conspired to have him convicted of a crime that she knew he did not 24 commit, as she had seen video evidence of a different man carrying a bat in 2015. Defendants 25 OPD officer Bass and Alameda County deputy district attorney Ford threatened and intimidated a 26 witness, telling the witness to lie and threatening to send the Riders after the witness, for the 27 purpose of maliciously prosecuting Plaintiff and as part of a conspiracy to have Plaintiff convicted 1 while in custody. See generally Dkt. No. 1. 2 C. Dismissal with Leave to Amend 3 The Court DISMISSES the complaint with leave to amend because it suffers from the 4 following deficiencies. 5 First, the complaint proffers vague and conclusory allegations. It is unclear what 6 happened. It is unclear how defendant Hicks’ false report or defendants Basa and Ford’s alleged 7 witness intimidation caused Plaintiff to be falsely and maliciously prosected. It is unclear whether 8 there was one malicious prosecution, or if each defendant’s actions resulted in a separate 9 malicious prosecution. It is also unclear for what crime Plaintiff was allegedly maliciously and 10 falsely prosecuted. It is also unclear what specific right was violated by each named defendant, 11 and if any federal law or constitutional provision was violated, as is required for federal question 12 jurisdiction and for bringing an action pursuant to 42 U.S.C. § 1983. The complaint repeatedly 13 states that each defendant “violated Plaintiff’s rights,” without further detail. 14 Second, the complaint violates the joinder rule set forth in Fed. R. Civ. P. 20(a)(2). Rule 15 20(a)(2) provides that all persons “may be joined in one action as defendants if: (A) any right to 16 relief is asserted against them jointly, severally, or in the alternative with respect to or arising out 17 of the same transaction, occurrence, or series of transactions or occurrences; and (B) any question 18 of law or fact common to all defendants will arise in the action.” Fed. R. Civ. P. 20(a)(2). The 19 upshot of these rules is that “multiple claims against a single party are fine, but Claim A against 20 Defendant 1 should not be joined with unrelated Claim B against Defendant 2.” George v. Smith, 21 507 F.3d 605, 607 (7th Cir. 2007). The claim against Santa Rita Jail arises out of a separate 22 occurrence as the claims regarding malicious/false prosecution against the other named 23 defendants, and must be brought in a separate action. In this action, Plaintiff may only pursue 24 relief for acts that arise out of the same transaction, occurrence, or series of transactions or 25 occurrences, and share a common question of law or fact. To seek relief for claims arising out of 26 other incidents or raising different questions of law, Plaintiff must bring separate actions. 27 Third, Plaintiff’s claims may be barred by the Heck doctrine. Pursuant to Heck v. 1 success in the action would necessarily imply the invalidity of the plaintiff’s conviction or 2 sentence, and the conviction or sentence has not yet been invalidated. Id. at 486–87. Where the 3 conviction or sentence has not yet been invalidated, the Section 1983 suit is barred no matter the 4 relief sought (damages or equitable relief) and no matter the target of the suit (conduct leading to 5 conviction or internal prison proceedings), see Wilkinson v.

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Tingle v. State of California, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tingle-v-state-of-california-cand-2024.