Watts v. Epps
- Jacquelyn Corley
- 3:24-cv-03913
- U.S. District Court · Northern District of California
- 2
In Watts v. Epps, Judge Corley dismissed Dante Watts’s case after he failed to timely amend a complaint that did not present a valid civil-rights claim.
Dante Watts, whose case was dismissed, and David Epps, the named defendant.
What happened
In Watts v. Epps, the court had previously dismissed Dante Watts’s civil-rights complaint because it did not present a legally recognizable claim for relief. The court gave him until October 4, 2024, to file an amended complaint correcting the problems and warned that the case could be dismissed if he did not do so.
Watts did not file an amended complaint or timely request more time. He later sent a letter saying he understood that he needed to exhaust administrative remedies and that problems obtaining legal papers prevented him from doing so. The court explained that its earlier order did not require exhaustion; it required him to file an amended complaint seeking relief available in a civil-rights case. The court therefore found that the letter did not excuse his failure to amend on time.
Judge Corley ordered the case dismissed and directed the Clerk to enter judgment and close the file. The opinion states that the case was dismissed without prejudice to the extent Watts intended to bring a habeas petition, which is a court challenge to unlawful custody or detention. The opinion does not state that the court decided the merits of any habeas petition.
The detailed version
- Watts v. Epps · No. 3:24-cv-03913
- Jacquelyn Corley
- Nov. 12, 2024
Background
Dante Watts brought a civil-rights complaint against David Epps. On September 4, 2024, the court dismissed the complaint because it did not present a cognizable claim for relief. The court gave Watts until October 4, 2024, to file an amended complaint that corrected the deficiencies and warned that the case would be dismissed if he did not do so.
Watts did not file an amended complaint, and he did not timely request an extension of the deadline. On October 23, 2024, the court received a letter in which Watts said he understood that he needed to correct an exhaustion-of-administrative-remedies problem. He said he had sent court papers to San Quentin’s prison law office for help, but that the papers were not returned to him and that mail containing court papers sent to his family was not given to them. He requested his “petition” so he could exhaust his remedies.
Court’s reasoning
The court explained that its earlier order did not require Watts to exhaust administrative remedies. Instead, the order required him to file a timely amended complaint seeking a type of relief available in this civil-rights action. Because the letter was filed after the amendment deadline, and because it did not excuse his failure to file an amended complaint or timely request more time, the court proceeded with dismissal.
The opinion also refers to the absence of a cognizable claim for damages under 42 U.S.C. § 1983, the federal civil-rights statute used for certain claims against state or local officials. It separately states that the matter was dismissed without prejudice to the extent Watts intended to bring a habeas petition. The opinion does not describe a merits decision on a habeas petition.
Disposition
The court ordered dismissal, directed the Clerk to enter judgment, and ordered the file closed. It dismissed the matter without prejudice to the extent Watts intended to bring a habeas petition. The opinion does not add a “with prejudice” qualification to the general dismissal. This was a procedural disposition based on the failure to file the required amended complaint, rather than a decision resolving the underlying civil-rights claim on its merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.