Laine v. Superior Court of California, County of San Joaquin

Background

Self-represented plaintiff Joshua Laine filed the lawsuit against the Superior Court of California, County of San Joaquin; San Joaquin Superior Court Judge Gus Correa Barrera; San Joaquin Superior Court Assistant Court Executive Officer Stephanie Bohrer; and California Attorney General Rob Bonta. The complaint asserted twelve causes of action arising from a domestic-violence criminal case against Laine that was pending in San Joaquin County Superior Court. Laine alleged that the defendants violated his rights and prosecuted him unfairly. He also applied to proceed without paying filing fees under 28 U.S.C. § 1915.

Screening and Venue

When a person seeks to proceed without paying filing fees, the court must screen the complaint to determine whether it states a claim for which relief may be granted. The court may also dismiss or transfer the case if venue—the proper federal district for the lawsuit—is improper.

The court explained that venue generally may be based on where defendants reside or where a substantial part of the events occurred. All defendants except Bonta resided in San Joaquin County, which is in the Eastern District of California. The court also found that a substantial part, if not all, of the events underlying Laine’s claims occurred there. Venue in the Northern District of California therefore depended on whether Laine had stated a claim against Bonta.

Allegations Against Bonta

Laine sued Bonta in both his official and personal capacities. The complaint alleged that Bonta conspired with the San Joaquin County court defendants and unnamed co-conspirators to violate Laine’s rights during the criminal proceedings. It also alleged that Bonta failed to supervise administrators and subordinates in the San Joaquin County District Attorney’s Office.

The court found the conspiracy allegation conclusory and unsupported by facts, so it disregarded that allegation. The court also held that claims seeking to hold Bonta responsible for the actions of prosecutors failed because prosecutors have absolute immunity under 42 U.S.C. § 1983 for conduct closely connected to prosecuting a criminal case. The court identified the challenged conduct as including alleged perjury and fraud concerning bail, failure to provide discovery, and allegedly improper changes to the criminal complaint. It also cited California Government Code section 821.6, which provides immunity for public employees for injuries caused by instituting or prosecuting judicial or administrative proceedings within the scope of employment, even when the employee acts maliciously or without probable cause.

Disposition

Because the complaint did not state a claim against Bonta, the court treated him as a sham defendant whose residence could be disregarded for venue purposes. The court found that venue was proper in the Eastern District of California and transferred the case there under 28 U.S.C. § 1406(a) so that that court could conduct the full required screening review under 28 U.S.C. § 1915. The order transferred the case; it did not complete the full screening of the complaint.