Vincent Lawrence Roberts v. Fairbanks Public Defenders

CourtDistrict Court, D. Alaska
DecidedDecember 15, 2025
Docket4:25-cv-00035
StatusUnknown

This text of Vincent Lawrence Roberts v. Fairbanks Public Defenders (Vincent Lawrence Roberts v. Fairbanks Public Defenders) is published on Counsel Stack Legal Research, covering District Court, D. Alaska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vincent Lawrence Roberts v. Fairbanks Public Defenders, (D. Alaska 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA

VINCENT LAWRENCE ROBERTS,

Plaintiff, Case No. 4:25-cv-00035-SLG v.

FAIRBANKS PUBLIC DEFENDERS,

Defendants.

ORDER OF DISMISSAL UPON SCREENING & NOTICE OF STRIKE On August 28, 2025, self-represented prisoner Vincent Lawrence Roberts (“Plaintiff”) filed a civil complaint against the Public Defender’s Office in Fairbanks, Alaska.1 Plaintiff’s Complaint challenges the constitutional adequacy of court- appointed defense attorneys in state court criminal cases and purports to be brought on behalf of a class of prisoners.2 Plaintiff also filed three petition-style documents signed by numerous prisoners who purportedly seek to proceed as class representatives or co-plaintiffs in this case.3 The Court has now screened Plaintiff’s Complaint in accordance with 28 U.S.C. §§ 1915(e) and 1915A.4 Upon review, the Complaint must be dismissed for

1 Docket 1. 2 Docket 1 at 1. 10-11. 3 Docket 1 at 10-12. 4 Under the Prison Litigation Reform Act, a federal district court must screen complaints brought by prisoners seeking relief against a governmental entity or officer or employee of a governmental entity, shall dismiss the case at any time if the court determines that failure to state a claim. The Court further finds that allowing Plaintiff leave to file an amended complaint would be futile.5 This dismissal counts as a “strike” as to Mr. Roberts only; this dismissal does not count a strike as to any other prisoners

because their claims were not adjudicated on the merits. DISCUSSION I. Plaintiff can only represent his own interests Vincent Roberts is the sole litigant listed on the docket. The 49 additional prisoners listed on the separate signature pages have not been added as plaintiffs

to the docket and are not considered co-plaintiffs in this case. A non-attorney self- represented litigant may represent only his own interests,6 and has “no authority to appear as an attorney for others than himself.”7 The signature sheets submitted with the Complaint do not add any individuals as parties to this case and a self- represented litigant cannot maintain a class action.8

the action: (i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). 5 Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034, 1041 (9th Cir. 2011) (affirming denial of leave to amend where amendment would be futile because the defects in the complaint could not be cured by additional factual allegations); Carrico v. City & Cnty. of San Francisco, 656 F.3d 1002, 1008 (9th Cir. 2011) (affirming denial of leave to amend where amendment would be futile because plaintiffs failed to allege a viable legal theory). 6 28 U.S.C. § 1654. 7 See Simon v. Hartford Life, Inc., 546 F.3d 661, 664 (9th Cir. 2008) (non-attorney plaintiff may not attempt to pursue claim on behalf of others in a representative capacity); Cato v. United States, 70 F.3d 1103, 1105 n.1 (9th Cir. 1995) (non-attorney party may not represent other plaintiffs). 8 See Federal Rule of Civil Procedure 23 (setting forth the prerequisites for maintaining Case No. 4:25-cv-00035-SLG, Roberts v. Fairbanks Public Defenders Federal Rule of Civil Procedure 20 allows for the permissive joinder of plaintiffs who assert claims arising out of the same transaction or occurrence and present common questions of law or fact. When appropriate, prisoners may join

together as self-represented litigants in a lawsuit, so long as they each pay “the full amount of a filing fee.”9 However, given that Plaintiff cannot state a viable civil rights claim against a state public defender or the public defender’s office under 42 U.S.C. § 1983, the joinder of other prisoners to this litigation who also cannot state a viable civil rights claim against public defenders is not warranted in this

case. II. Civil Rights Claims under 42 U.S.C. § 1983 (“Section 1983”) To state a claim for relief under Section 1983, a plaintiff must allege plausible facts that, if proven, would establish that (1) the defendant acting under color of state law (2) deprived the plaintiff of rights secured by the federal Constitution or federal statute.10 To act under color of state law, a complaint must allege that the

a class action). 9 Johnson v. High Desert State Prison, 127 F.4th 123, 133–34 (9th Cir. 2025) (explaining that prisoners “can proceed under [28 U.S.C.] § 1914 and decide amongst themselves how to apportion the cost upfront. For instance, they can each pay $175, or maybe one of them has more funds than the other and pays the entire $350. Alternatively, they can proceed under § 1915 and each pay $350 over many months, and perhaps over many years . . . [B]y giving prisoners this choice, and by perhaps incentivizing prisoners to proceed under § 1914, Congress did indeed accomplish its goals of treating indigent IFP prisoners like ‘ordinary non-indigent plaintiffs’ while simultaneously ensuring that prisoners retain access to court.”). 10 Gibson v. United States, 781 F.2d 1334, 1338 (9th Cir. 1986). Case No. 4:25-cv-00035-SLG, Roberts v. Fairbanks Public Defenders defendant acted with state authority as a state actor.11 To be deprived of a right, the defendant’s action must either violate a right guaranteed by the Constitution or an enforceable right created by a federal statute.12 Section 1983 does not confer

constitutional or federal statutory rights. Instead, it provides a mechanism for remedying violations of pre-existing federal rights.13 III. Plaintiff cannot bring Section 1983 claims against a public defender or a public defender’s office An attorney appointed to represent a criminal defendant in a state court proceeding is “as a matter of law, . . . not a state actor,”14 an essential element of a Section 1983 claim. Such an attorney, whether from the Office of Public Advocacy, the Public Defender Agency, or by contract, is “no doubt, paid by

government funds and hired by a government agency. Nevertheless, his function was to represent his client, not the interests of the state or county.”15 “Except for the source of payment, . . . the duties and obligations are the same whether the lawyer is privately retained, appointed, or serving in a legal aid or defender

11 West v. Atkins, 487 U.S. 42, 49 (1988) (quoting United States v. Classic, 313 U.S. 299, 326 (1941)). 12 Gonzaga Univ. v. Doe, 536 U.S. 273 (2002). See also Health & Hosp. Corp.

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