Young v. Sheldon

Background

Joseph Dale Young, proceeding without a lawyer, sued Nicole Sheldon in her official capacity as a probation officer and the County of Santa Cruz. His complaint asserted negligence and constitutional-rights claims under 42 U.S.C. § 1983. He alleged that Sheldon left his vehicle unlocked while he was in custody for a probation violation, after which the vehicle was broken into.

Young later sought a temporary restraining order, an emergency court order intended to prevent immediate harm. He asked the court to prohibit defendants from requiring him to enroll in a sober living environment as a condition of probation or remanding him to custody. Young alleged that defendants imposed the condition in retaliation for filing the lawsuit. He filed a duplicate motion, and the court treated both filings as one motion. Defendants opposed the request.

Legal standard

The court applied the same standard used for a preliminary injunction. Young had to show a likely chance of success on the merits, a likely risk of irreparable harm without immediate relief, that the balance of hardships favored him, and that an injunction would serve the public interest. The court noted that a lesser showing concerning the merits can sometimes suffice when the balance of hardships sharply favors the plaintiff, but the plaintiff must still satisfy the other requirements.

Court’s analysis

The court concluded that Young had not shown a likely chance of success. It held that merely alleging that a new probation condition followed the filing of the lawsuit was insufficient to establish retaliation. The court also considered sworn affidavits from the district attorney and probation officer. Those affidavits stated that they had not heard about the lawsuit until after Young filed the temporary-restraining-order motion. The probation officer further stated that he had not represented, suggested, or implied that Young would be returned to custody if he did not enter a sober living environment by November 21, 2025. The court found that Young had presented no evidence supporting his theory.

The court also found that Young had not plausibly alleged irreparable harm. Although he referred to losing access to the courts and having his First Amendment activity chilled, he did not provide factual allegations showing that he faced an imminent risk of those injuries. Because Young failed to establish both a likely chance of success and irreparable harm, the court did not address the remaining injunction factors.

Disposition

The court DENIED the motion for a temporary restraining order. The order is without prejudice to Young filing a motion for a preliminary injunction that could be heard with proper notice to defendants on the court’s regular calendar. The order terminated ECF Nos. 13 and 18.