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 Yesenia Sanchez as the sole defendant and applied to proceed without prepaying filing fees. The court granted that application, directed the clerk to issue a summons, and directed the U.S. Marshal to serve Sanchez.

When the Marshal attempted service, the County of Alameda said it would not accept service for Sanchez because the County was not a named party. Because Reeves was representing herself, the court construed her claim as one against County of Alameda, through Sheriff Yesenia Sanchez in her official capacity. The court issued a revised summons using that description, but the County again refused service because Sanchez remained the only party listed in the complaint.

Legal basis

The court explained that the ADA applies to discrimination against people detained in county jails. It also explained that the ADA permits private citizens to seek money damages from public entities that violate the statute. A plaintiff may sue a public entity or an employee acting in an official capacity for damages under the ADA, but may not sue an individual for an ADA violation. The court therefore identified County of Alameda, rather than Sanchez individually, as the proper defendant for the claim described in the complaint.

Order

The court ordered Reeves to file a First Amended Complaint by August 28, 2025, naming “County of Alameda” as the defendant. After the amended complaint is filed, the clerk must issue a revised summons addressed to County of Alameda, and the U.S. Marshal must serve the amended complaint, attachments, Reeves’s affidavit, and the court’s orders without prepayment of fees. The order did not decide whether Reeves will ultimately prevail on the ADA claim.