Allaf-Motedayen v. Sonoma County Child Protective Services

Background

Magistrate Judge Sallie Kim recommended dismissal because Farzad Allaf-Motedayen had not filed an amended complaint by the April 28, 2025 deadline. Allaf-Motedayen then filed a first amended complaint on May 7, 2025, together with a request that the court accept the late filing. The court granted that request and declined to adopt the recommendation based on the missed deadline.

The court had previously allowed Allaf-Motedayen to proceed without paying the filing fee and had screened the original complaint under 28 U.S.C. § 1915(e)(2). That screening found no cognizable claims. The court screened the amended complaint as well.

Claims and analysis

The amended complaint concerned a 2017 state court criminal conviction and several ongoing state court proceedings, including a juvenile dependency matter, an unlawful-detainer action, proceedings involving Allaf-Motedayen’s wife, and a criminal case involving an alleged restraining-order violation.

The court held that it lacked jurisdiction to issue orders enjoining, dismissing, or revising rulings in ongoing state court proceedings. It also held that a challenge to the 2017 conviction could proceed in federal court only after exhaustion of available state remedies. Because the complaint did not allege exhaustion or an applicable exception, it did not state a claim for relief from that conviction.

Claims against a state court judge and a state court commissioner were barred by judicial immunity for acts performed in their judicial roles. Claims against a state court clerk and a federal court clerk were barred by quasi-judicial immunity for their handling of filed documents.

Claims concerning the removal of children and arrests were not adequately pleaded against Sonoma County or the City of Rohnert Park because the complaint did not allege that the actions resulted from a municipal policy or practice. The claims were also inadequately pleaded against individual defendants because the complaint grouped unnamed people together without alleging what each person did or facts addressing qualified immunity. The court likewise found unsupported the allegations that Allaf-Motedayen’s wife acted together with government employees to violate his rights.

Finally, the court found that the alleged denial of body-camera footage did not state a Brady claim because the complaint did not allege that the footage was favorable to the accused or that its denial caused prejudice. Because no cognizable federal claim was stated, the court declined to exercise supplemental jurisdiction over the state-law claims.

Disposition

Judge Chesney dismissed the amended complaint, with leave to amend. The order granted the motion for acceptance of the late-filed amended complaint and allowed Allaf-Motedayen to file a second amended complaint by June 6, 2025.