Scott v. Rahimi

Background

Christopher Davon Scott filed a complaint under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state law for violating federal rights. He alleged that sheriff’s deputies at the San Mateo County Jail violated his “Faretta rights” by denying him access to phone calls, books, and electronic tablets on several occasions in February and March 2025. The court reviewed the complaint under the required screening process for a prisoner seeking relief from government officials.

Court’s analysis

The court held that Scott’s allegations did not state a claim for violating the right to self-representation. Under Faretta v. California, a criminal defendant has a right to represent himself at trial, but that right is violated only when a trial judge refuses to allow self-representation. The court explained that sheriff’s deputies cannot violate that right.

The court said the described restrictions might support a First Amendment access-to-courts claim, but Scott had to allege an actual injury—such as missing a filing deadline or losing a legal claim because of the interference. The court found that he had not alleged such an injury. It also found that he had not identified the person responsible for the alleged restrictions or described each defendant’s actions specifically enough. Although Scott named Deputies Rahimi and Nunez in the complaint, those names did not appear in the factual allegations, and the complaint did not identify the people who allegedly denied the calls or materials.

Disposition

The court dismissed the complaint with leave to amend on or before August 1, 2025. The court directed Scott to file a first amended complaint using the required caption, case number, words, and court form; include all claims and defendants he wished to pursue; and avoid incorporating earlier filings by reference. The court stated that failure to file a proper amended complaint by the deadline would result in dismissal of the action under Federal Rule of Civil Procedure 41(b), without further notice. The court also instructed Scott to keep the court informed of any address change and comply with court orders.