Lacy v. U. S. Attorney's Office

Background

Plaintiffs Edward Dwayne Lacy and Xavier Dwayne Lacy proceeded without lawyers and moved to proceed in forma pauperis, meaning without paying the filing fees. The court found that they could not pay the full fees, costs, or security required to pursue the action.

The complaint concerned an alleged incident at a Social Security Administration office in Hayward, California. Plaintiffs alleged that, during Edward Lacy's April 2013 attempt to pick up benefits for himself and his son, Social Security Administration employees verbally harassed and threatened him. They further alleged that a guard handcuffed and pepper sprayed Edward before police arrived, that police placed a second pair of handcuffs on him, and that the Hayward Fire Department threw water on his face. Plaintiffs also alleged that officials did not respond to their complaints. They asserted claims under the Fourth and Fourteenth Amendments, several statutes, and unidentified state laws.

Screening and Claim Preclusion

Under 28 U.S.C. § 1915, the court must screen a complaint filed by someone seeking to proceed without paying fees. The court must dismiss the case if the complaint fails to state a legally sufficient claim. Although courts read complaints filed by people without lawyers liberally, they do not have to accept conclusory allegations, unsupported factual deductions, or unreasonable inferences.

The court determined that the current case was barred by res judicata, also called claim preclusion. Claim preclusion prevents a party from bringing claims that were already finally decided or that could have been raised in an earlier case. The court identified three required elements: the two cases must involve the same claims, a final judgment on the merits, and the same parties or parties legally connected to them.

The court found all three elements. First, both cases arose from the same alleged conduct during the same visit to the Social Security Administration office on April 1, 2013. The court stated that variations in how the claims were described, including listing statutory claims in the caption, did not change the fact that they arose from the same events. Second, the court found the same parties or legally connected parties, noting that defendants added by handwriting in the amended complaint had already appeared elsewhere in the earlier complaint and that the two complaints sought identical monetary damages from the same parties. Third, the court found that the earlier case had resulted in a final judgment on the merits because it had been dismissed without leave to amend. The court relied on Federal Rule of Civil Procedure 41(b), which generally treats a dismissal as an adjudication on the merits except for specified dismissals, including those for lack of jurisdiction, improper venue, or failure to join a required party.

Disposition

The court DENIES Plaintiffs' motion to proceed in forma pauperis. It further DISMISSES the complaint without leave to amend because allowing an amendment would be futile. The Clerk was directed to enter judgment in favor of Defendants and close the case. The court cautioned Plaintiffs against filing serial cases against Defendants and stated that they must appeal to the Ninth Circuit if they disagree with the rulings.