Card v. Alameda County District Attorney's Office

Background

Christopher Lee Card filed the lawsuit under 42 U.S.C. § 1983, a federal law that permits claims for violations of federal rights by a person acting under state law. Card represented himself and was in custody at Santa Rita Jail. He sought monetary damages, punitive damages, and injunctive relief concerning events connected to his state criminal proceedings and competency hearings.

The complaint named 20 defendants in their individual and official capacities, including the Alameda County District Attorney’s Office, the Alameda County Public Defender’s Office, district attorneys, public defenders, psychologists, judges, California State Bar investigators, and Contra Costa County. Card alleged claims including malicious prosecution, double jeopardy, conspiracy, obstruction of justice, destruction of evidence, perjury, defamation, judicial misconduct, attorney misconduct, falsification of documents, and mental-health or disability violations.

Because Card was a prisoner seeking relief from governmental entities or employees, the court screened the complaint under 28 U.S.C. § 1915A. That screening required the court to identify claims that were frivolous, malicious, inadequately pleaded, or barred because a defendant was immune from monetary relief.

Injunctive and Declaratory Relief

The court applied the Younger abstention doctrine, which generally prevents a federal court from interfering with an ongoing state criminal case through an injunction or similar court order. The court found that all three required conditions were met: Card’s state criminal proceedings were ongoing; the prosecution implicated important state interests; and Card could present his federal claims in the state trial and appellate courts.

The court also found that Card did not plausibly allege the exceptional circumstances that could avoid abstention, such as immediate and irreparable harm, bad faith or harassment by the state, or bias in the state tribunal. The court therefore dismissed Card’s claims for injunctive relief. It did not state that this dismissal was with or without prejudice.

Monetary-Damages Claims

The court dismissed with prejudice Card’s claims for monetary damages against the defendants in their official capacities. It treated those claims as claims against the governmental entities and concluded that the Eleventh Amendment barred the damages claims because there was no waiver of that protection.

The court dismissed Card’s individual-capacity claim against Judge Goodman because the challenged decision was made in the judge’s judicial capacity and was protected by absolute judicial immunity.

The court dismissed claims against the Alameda County District Attorney’s Office and the named prosecutors because prosecutors are absolutely immune from liability for conduct performed as advocates in starting and pursuing a criminal case.

The court dismissed Card’s § 1983 claims against the Alameda County Public Defender’s Office and the public defenders based on the conclusion that public defenders do not act under color of state law when performing traditional lawyer functions, including representing a client and determining the client’s mental competency.

The court dismissed all claims against the court-appointed psychologists because witnesses have absolute immunity for testimony in earlier state or federal court proceedings, including allegedly false testimony.

The court dismissed the claims against California State Bar investigators Espitia and Vaghashia because absolute immunity can protect agency officials performing functions similar to those of judges and prosecutors. It also dismissed Card’s claim against Contra Costa County because he did not allege a basis for municipal liability other than respondeat superior, meaning liability based only on the employer’s relationship with its personnel, which is insufficient under § 1983.

Disposition

The court dismissed the action because Younger abstention applied to Card’s claims for injunctive relief. It dismissed with prejudice all claims for monetary damages against the named defendants in their official capacities. It dismissed without leave to amend all claims for monetary damages against Judge Goodman, the Alameda County District Attorney’s Office, the Alameda County Public Defender’s Office, the district attorneys, the public defenders, the court-appointed psychologists, the State Bar investigators, and Contra Costa County.

The court certified that any appeal proceeding without payment of filing fees would not be taken in good faith and directed the clerk to close the file. Judge Araceli Martinez-Olguin signed the order.