Doe v. County of Sonoma
- Jonato
- 3:16-cv-05195
- U.S. District Court · Northern District of California
- 3
In John Doe v. Rob Bonta, Judge Jonato dismissed Doe’s third amended complaint with prejudice because it did not plausibly state a due-process claim.
John Doe’s challenge to California’s Section 5250 mental-health treatment procedures was dismissed with prejudice. The order also rejected the complaint’s attempt to obtain relief concerning federal firearm regulations from state officials who did not control those regulations.
What happened
In John Doe v. Rob Bonta, John Doe challenged California’s procedures for involuntary mental-health treatment under Section 5250 of the Lanterman-Petris-Short Act. He argued that the procedures violated due process because hearings were not before judges, attorneys were not guaranteed, evidence rules did not apply, and the proof standard was too low.
Doe also discussed the loss of firearm possession or ownership under federal law. The defendants argued that the complaint should be dismissed because Doe lacked standing and had not stated a plausible claim. The court chose to address the lack of a plausible claim rather than extend the case to examine the standing issues.
Judge Jonato dismissed the third amended complaint with prejudice and closed the case. The court relied on prior decisions rejecting Doe’s due-process arguments and noted that the defendants did not control federal firearm regulations; it also concluded that further amendment could not cure the defects.
The detailed version
- Doe v. County of Sonoma · No. 3:16-cv-05195
- Jonato
- July 11, 2024
Background
John Doe, proceeding without a lawyer and under a pseudonym, challenged the involuntary mental-health treatment procedures in Section 5250 of California’s Lanterman-Petris-Short Act. The court had dismissed three earlier complaints. This order addressed Doe’s third amended complaint and the motion to dismiss filed by Rob Bonta and Tomas J. Aragon, M.D., who were sued in their official capacities as California’s Attorney General and the Director of the California Department of Public Health.
Claims and arguments
The court understood Doe to be arguing that Section 5250 violated due process because certification-review hearings were not held before a judicial officer, there was no right to an attorney, the rules of evidence did not apply, and the standard of proof was too low. The complaint also discussed Doe’s belief that his mental-health history caused him to lose firearm possession or ownership under federal law. Doe primarily sought court orders declaring the statute unconstitutional and stopping the state officials from enforcing state laws.
The defendants moved under Federal Rule of Civil Procedure 12(b)(1), which concerns federal subject-matter jurisdiction and standing, and Rule 12(b)(6), which concerns whether a complaint states a plausible legal claim. The court noted questions about whether Doe still lived in California or remained potentially subject to Section 5250, and whether the requested relief would remedy his alleged injuries. But because Doe had personally been treated under Section 5250 procedures in California and the defendants’ standing argument was underdeveloped, the court decided to address the complaint’s lack of plausibility instead.
Court’s reasoning
The court said that established precedent foreclosed Doe’s due-process claims. It relied on a Ninth Circuit decision holding that a Section 5250 hold requires a probable-cause hearing before an impartial decisionmaker, but not necessarily a judicial officer. It also cited a Supreme Court decision stating that due process does not require a judicial determination, appointed counsel, adherence to evidence rules, or a clear-and-convincing-evidence standard for involuntary psychiatric medication. The court further cited a California appellate decision concerning hearsay in civil commitment proceedings.
As to the firearm issue, the court stated that none of the defendants controlled federal firearm-possession regulations and that none of the claims in the complaint could conceivably affect those regulations.
Disposition
The court dismissed the third amended complaint. It stated that Doe had already received an appeal and multiple opportunities to plead a plausible claim, and that the deficiencies could not be cured by amendment. The dismissal was with prejudice, and the case was closed. Judge Jonato issued the order on July 11, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.