Card v. County of Alameda

Background

Christopher Lee Card, who was confined at Santa Rita Jail, filed this civil-rights action under 42 U.S.C. § 1983 without a lawyer. The court had allowed him to proceed without prepaying the filing fee and screened his complaint under 28 U.S.C. § 1915A, which requires an early review of a prisoner’s claims against a government entity or government official.

Card sought punitive and monetary damages. His handwritten complaint concerned events related to his Alameda County criminal case, including proceedings about his mental competency and evaluations by psychologists. He also named Alameda County and eleven people in their individual capacities: a deputy district attorney, psychologists, public defenders, and deputy county counsel. Among other allegations, he asserted conspiracy, misconduct, deprivation of civil rights, perjury, document falsification, abuse of process, and attorney misconduct. He also identified claims under 18 U.S.C. §§ 241 and 242 and asserted negligence and respondeat-superior theories against a deputy county counsel.

The court noted that Card had filed earlier related actions involving some of the same events and defendants. In one earlier action, the court dismissed federal claims as barred by the rule from Heck v. Humphrey. In another, it dismissed requests for an injunction based on a rule requiring federal courts to refrain from interfering with certain ongoing state proceedings, and dismissed remaining damages claims without leave to amend.

Screening standard

To state a claim under § 1983, a plaintiff must allege that a federal constitutional or statutory right was violated by a person acting under state law. During screening, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also stated that it must read filings by people representing themselves liberally.

Reasons for dismissal

- Deputy District Attorney Kevin Ikuma: The court dismissed the claims arising from Ikuma’s prosecutorial acts because a prosecutor has absolute immunity for conduct performed as an advocate in initiating or pursuing a criminal case. - Public defenders Brendon Woods, Youseef Elias, Joshi Valentine, Sue Young Ra, Aundrea Brown, and Daniel Duvernay: The court dismissed the § 1983 claims alleging deficient representation. It held that public defenders do not act under color of state law when performing traditional defense functions, including representation concerning a client’s mental competency. - Psychologists Dr. Amy Watt and Dr. Marlin Griffith: The court dismissed the claims based on alleged perjury in statements to the superior court. It held that witnesses have absolute immunity from liability for testimony in earlier state or federal court proceedings, even when the testimony is alleged to be perjured. - Deputy County Counsel Jill Sazama and Donna Ziegier: The court dismissed the claims because absolute immunity can protect officials performing prosecutorial or judicial functions, and because the complaint failed to state a § 1983 claim against them to the extent they acted in a prosecutorial role. - Alameda County: The court dismissed the claim against the County because Card alleged municipal liability only through respondeat superior—meaning liability based solely on the County’s responsibility for its employees. The court held that this theory is not sufficient for § 1983 municipal liability.

Ruling and disposition

Judge Araceli Martinez-Olguin dismissed without leave to amend all claims for punitive and monetary damages against all named defendants. The order does not separately explain a disposition for every request for injunctive relief, although the introduction states that the complaint was dismissed. The court also certified that an appeal proceeding without prepaying fees would not be taken in good faith and ordered the Clerk to close the file.