Smiley James Harris, A.R. v. U. S. DEPT. OF JUSTICE, et al.

Background

Smiley James Harris, A.R., proceeding without a lawyer, sued the U.S. Department of Justice, the California Department of Justice, the State of California, the California Department of Motor Vehicles, the County of Lake, the City of Clearlake, and the Clearlake Police Department. The complaint appears to concern arrests and convictions between 2015 and 2022 that Harris described as false and maliciously prosecuted. Harris alleged that these events led to incarceration and loss of a vehicle. He also connected the alleged misconduct to defendants’ failure to recognize a “commercial” affidavit and a “clarification of citizenship” affidavit.

The complaint cited 18 U.S.C. §§ 241, 242, 245(1), and 1346; 42 U.S.C. §§ 1983, 1985(3), and 1986; and the First, Fourth, Fifth, and Fourteenth Amendments. The defendants moved to dismiss under Rule 12(b)(6), which tests whether a complaint contains enough legally sufficient facts to state a claim.

Court’s Analysis

The court held that the complaint did not give defendants fair notice of the claims. It did not identify clearly which investigations, arrests, convictions, or related policies allegedly violated the law or caused harm. Instead, it provided a series of superior-court case numbers and conclusory allegations.

The court also identified several independent problems with the asserted claims:

- Claims for damages based on unconstitutional convictions or imprisonment were barred by the rule from Heck v. Humphrey because Harris did not allege that the convictions or sentences had been reversed, expunged, declared invalid, or called into question through a court order concerning detention. - Claims based on prosecutorial conduct were barred by state-sovereign immunity under the Eleventh Amendment and by absolute immunity for prosecutors acting in their prosecutorial roles. - Claims under 42 U.S.C. §§ 1983, 1985(3), and 1986 were time-barred under the limitations periods discussed by the court. The court stated that the most recent conviction identified in the complaint occurred in 2022. - The allegations against the County of Lake appeared to rely on automatically attributing responsibility to the county for actions by courts or district attorneys. The court held that this was not a legally valid theory for municipal liability under § 1983.

Disposition

The court granted the defendants’ motion to dismiss. It did not grant leave to amend, concluding that amendment would be futile in light of the defects identified in the complaint and Harris’s prior failures to state a claim in two substantially similar cases. The order therefore does not allow Harris to file an amended complaint in this action under the ruling stated in the opinion.