Jackson v. Borla
- Wise
- 5:25-cv-04304
- U.S. District Court · Northern District of California
- 3
In Jackson v. Borla, Judge Wise dismissed Jackson’s pro se civil-rights complaint without prejudice because his requested release belonged in a habeas petition.
Derrick Eugene Jackson’s complaint was dismissed without prejudice; the order did not decide whether his sentence or release-date claims were ultimately valid.
What happened
In Jackson v. Borla, Derrick Eugene Jackson, a state prisoner, sued under a federal civil-rights law over changes to his release date and sentence. He sought release, dismissal of his convictions, and damages.
The court explained that a civil-rights lawsuit cannot be used to obtain immediate or faster release from custody or dismissal of state convictions. Those requests must be brought in a petition challenging the legality of the imprisonment. The court also discussed limits on damages claims that would undermine an existing conviction or sentence.
Judge Wise dismissed the complaint without prejudice to Jackson filing a petition under 28 U.S.C. § 2254. The court also ordered the clerk to send Jackson a blank petition form and close the file.
The detailed version
- Jackson v. Borla · No. 5:25-cv-04304
- Wise
- July 11, 2025
Background
Derrick Eugene Jackson, a state prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. He alleged that changes to his release date and a change in law made his sentence invalid. He sought immediate release, dismissal of his convictions, and monetary damages.
Jackson named Division of Adult Institutions correctional case records analysts A. Digirolamo and R. Epps, along with Folsom State Prison employees S. Haili, J. Gelein, C. Evans, and P. Crosby. The excerpt identifies additional allegations and party information incompletely.
Court’s Analysis
The court screened the complaint under the Prison Litigation Reform Act. It explained that Section 1983 is generally used to challenge prison conditions, but it cannot be used to obtain release from custody or dismissal of state convictions. A request for immediate or faster release must instead be brought through a habeas petition—a court challenge to the lawfulness or duration of confinement—under 28 U.S.C. § 2254.
The court also addressed Jackson’s request for damages. It stated that a prisoner generally cannot obtain damages for unlawful imprisonment when success would undermine an existing conviction or sentence unless that conviction or sentence has first been reversed, expunged, declared invalid, or called into question by a federal court’s habeas ruling. The opinion’s discussion of this point ends mid-sentence in the provided text, but the court concluded that Jackson’s damages claims were barred while he remained in custody under the state criminal judgment and sought release and dismissal of his convictions.
The court declined to convert the civil-rights complaint into a habeas petition, explaining that a prisoner should file a habeas petition containing the relevant information and requested relief.
Disposition
Judge Wise ordered that Jackson’s complaint be dismissed without prejudice to seeking relief through a habeas petition. The court directed the clerk to send Jackson a blank 28 U.S.C. § 2254 form and ordered the file closed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.