Garrison v. Santa Clara County

Background

Steven Garrison, identified as an inmate in Santa Clara County Jail, filed a civil-rights complaint without an attorney against Santa Clara County and several county officials. The complaint was brought using 42 U.S.C. § 1983 and also asserted violations of the Racketeer Influenced and Corrupt Organizations Act and treason. The court separately granted Garrison permission to proceed without prepaying the filing fee.

Garrison made a series of allegations that the court described as far-fetched. Among other things, he alleged that the County was connected to the murders of thousands of children; that Deputy Flores had raped 30,000 inmates; that Donald Trump had ordered the extermination of Latino babies and had gassed millions of people; that a judge had participated in millions of mass killings; and that psychiatric medications contained fentanyl and anthrax. He also filed a motion seeking the defendants’ arrests and another seeking to identify the defendants’ counsel and hold the federal courts in contempt.

Screening standard

Under 28 U.S.C. § 1915A, a federal court must screen a prisoner’s complaint against a governmental entity or governmental official. The court must dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. A claim is frivolous when it rests on an indisputably meritless legal theory or lacks any factual basis. The court may reject factual allegations that are irrational or wholly incredible, although this screening process is not meant to resolve ordinary factual disputes.

Court’s analysis

The court found that Garrison’s allegations about mass murders, mass rapes, extermination, gassing, and dangerous substances in psychiatric medication were wholly incredible and delusional. It therefore determined that the claims were frivolous under § 1915A. The court also found the motions frivolous because it lacked authority to hold the federal courts in contempt and because there were no valid grounds to arrest the defendants.

Disposition

The case was dismissed without leave to amend as frivolous. Garrison’s motions to arrest the defendants and to hold the United States Courts in contempt were also denied as frivolous. The clerk was directed to enter judgment, close the file, and terminate docket numbers 8 and 9.