Smith v. Humboldt County Sheriff's Office Correctional Facility

Background

Ryan Thomas Smith brought this action without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state or local actors. The complaint concerns events that occurred while Smith was housed at the Humboldt County Sheriff’s Office Correctional Facility. In a March 22, 2024 screening order, the court found that the complaint stated either an Eighth Amendment or Fourteenth Amendment claim, ordered service on the defendant, and set a deadline for the defendant to file a dispositive motion.

The deadline was June 21, 2024. The defendant, which was represented by counsel, did not file a dispositive motion or tell the court by that deadline that it believed the case could not be resolved by summary judgment. Court staff reminded defense counsel about the missed deadline in July and September, but the defendant did not seek an extension at those times. After the court issued an order requiring the defendant to explain why default should not be entered for failing to defend the case, the defendant responded and attached a proposed summary judgment motion. It then formally moved for permission to file the motion late.

Reasons for Denial

The court denied the motion for an extension of time. First, the request for an extension was itself filed about three and a half months after the deadline, even though the court’s screening order and standing order required requests to extend deadlines to be filed before the relevant deadline.

Second, the motion did not comply with Civil Local Rule 6-3. That rule required a declaration describing efforts to obtain an agreement from the opposing party to change the deadline, along with other information and a proposed order. The defendant did not provide the required declaration or proposed order. Defense counsel also admitted at a hearing that he had not contacted Smith about the action.

Third, the court found that the defendant had not shown “excusable neglect,” the legally recognized reason that may permit a court to extend an expired deadline. The court considered the factors identified in Pioneer Investment Services Co. v. Brunswick Associates: the reason for the delay and whether it was within the moving party’s control, good faith, the length and effect of the delay, and possible prejudice to the opposing party.

The first factor weighed heavily against the defendant. The court found that the asserted staffing problems, workload, and illness did not explain why the defendant could not timely request an extension or file the summary judgment motion. The court noted that multiple attorneys remained available during relevant periods, that the proposed motion relied on jail records that had long been available, and that defense counsel acknowledged failing to read the portion of the order setting the deadline. Counsel also acknowledged that nothing prevented him from informing the court earlier about the problems.

The court treated the good-faith and delay-impact factors as neutral. It found no indication of bad faith, but also found no basis for an affirmative finding that the defendant acted in good faith after taking no action for months despite two reminders. The record was silent about actual prejudice to Smith, although his filings indicated that he had evidence concerning the merits and wanted discovery, creating a risk of harm to his case preparation.

Settlement Referral and Disposition

The court DENIED the defendant’s motion for an extension of time to file a dispositive motion. The order did not decide the underlying civil-rights claims or the proposed summary judgment motion on their merits.

The court also REFERRED the case to Magistrate Judge Robert Illman for a judicial settlement conference under the Pro Se Prisoner Mediation Program. The referral was coordinated with another case involving essentially the same parties but different causes of action. The parties were ORDERED to file a joint status report within 30 days after the settlement proceedings conclude, addressing settlement, any further settlement proceedings, a discovery plan, a case schedule, and issues required by Federal Rule of Civil Procedure 16.