II v. Chauvin

Background

Abdul Rahim Sabir II filed a complaint under 42 U.S.C. § 1983, a federal law that allows claims for violations of federal rights by people acting under state law. The complaint named various people and institutions, including the St. Louis Police Department in Missouri, the DeKalb County Jail in Georgia, Joe Biden, Derek Chauvin, and others. Sabir also referred to his confinement in the San Francisco County Jail, but stated only that he was not being sent to Atlanta, Georgia.

Screening standard

The court reviewed the complaint under federal prisoner-screening laws. Those laws require the court to identify claims that are legally sufficient and dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant who is legally protected from such relief. To state a § 1983 claim, a plaintiff must allege both a violation of a right protected by the Constitution or federal law and conduct by a person acting under state law.

Court’s analysis

The court held that the complaint failed to state any claim for relief. It explained that claims based on events in Georgia and Missouri could not be heard in the Northern District of California. The court instructed Sabir that an amended complaint must allege claims arising from events within that district.

The court also required Sabir to allege specific facts connecting each particular defendant to the specific wrongdoing alleged. It explained that § 1983 liability depends on an individual defendant’s own acts or omissions and that a defendant cannot be held liable unless the defendant was an integral participant in the unlawful conduct.

Disposition

The court DISMISSED the complaint with leave to file a first amended complaint on or before May 1, 2026. The amended complaint must use the caption and civil case number in the order, state “FIRST AMENDED COMPLAINT” on its first page, use the court’s form, include every claim and defendant Sabir wishes to pursue, and not simply incorporate the earlier complaints. The order warns that failure to file a proper amended complaint by May 1, 2026, may lead to dismissal of the action under Federal Rule of Civil Procedure 41(b) for failure to prosecute.

The order also states that Sabir must file a change-of-address notice in each case whenever his address changes. It notes that mail returned as undeliverable and failure to update his address may lead to dismissal under Rule 41(b).