Reeves v. Sanchez

Background

Linda Joyce Reeves filed a complaint under the Americans with Disabilities Act (ADA), alleging that she suffered injuries while housed at Santa Rita Jail. She named Alameda County Sheriff Yesenia Sanchez as the sole defendant. Reeves also applied to proceed without prepaying filing fees, and the court granted that application on April 14, 2025.

The court previously directed the clerk to issue a summons and the U.S. Marshal to serve Sanchez. When the Marshal attempted service, Alameda County said it would not accept service for Sanchez because the county was not a named party.

Court’s analysis

The court explained that the ADA prohibits discrimination based on disability and applies to discrimination against people detained in county jails. The court further stated that the ADA permits private citizens to seek money damages from public entities that violate the statute. Citing Ninth Circuit and other federal decisions, the court explained that individual prison or jail officials are not the proper defendants for an ADA discrimination claim; the public entity responsible for the alleged discrimination is the proper defendant.

Because Reeves was representing herself, the court construed her claim as one against the County of Alameda, through Sheriff Yesenia Sanchez in her official capacity.

Orders

The court ordered the clerk to issue a revised summons addressed to “County of Alameda, by and through Sheriff Yesenia Sanchez in her official capacity,” at the address stated in the order. It also ordered the U.S. Marshal for the Northern District of California to serve the defendant, without requiring advance payment of fees, with the complaint and attachments, Reeves’s affidavit, and the court’s orders.

Because the defendant had not been served, the court vacated the July 3, 2025 case management conference. The order addressed the proper defendant and service; it did not decide whether Reeves’s ADA claim would ultimately succeed.