Adams v. FBI San Francisco Field Office Supervisor and Agents

Background

Henry D. Adams, a state prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against the Federal Bureau of Investigation’s San Francisco Field Office supervisor and agents. The court stated that Adams would be allowed to proceed without paying filing fees in a separate order.

Adams alleged that the defendants violated his Fourteenth Amendment due-process rights by failing to investigate more than 30 letters he sent to the FBI Field Office between May 2017 and May 14, 2019. The letters described alleged wrong medication, retaliation, assaults, threats, falsified records, hidden or tampered evidence, pressure to accept a plea deal, identity-related credit lines, stolen property, inadequate medical care, the use of informants, and other alleged criminal activity by law-enforcement agencies and others. Adams sought money damages and release from what he called his false imprisonment and illegal sentence.

Court’s Analysis

The court screened the complaint under 28 U.S.C. § 1915A, which requires a preliminary review of a prisoner’s claims against governmental entities or their employees. At this stage, the court must dismiss claims that are frivolous, fail to state a legally valid claim, or seek money from an immune defendant. The court also said that it must read complaints filed by people without lawyers liberally.

To state a claim under § 1983, a plaintiff must allege that a federal right was violated and that each defendant personally caused or participated in causing the violation. The court held that Adams had not identified a constitutional right requiring the FBI defendants to investigate his grievances. It explained that there is no constitutional right to an investigation by government officials unless another recognized constitutional right is also involved.

The court further found that Adams’s allegations were presented conclusorily, without factual support, and that he did not allege each defendant’s personal involvement in a constitutional violation. The court also explained that § 1983 requires conduct under color of state authority and an actual causal connection between each defendant’s conduct and the alleged deprivation. It concluded that no such connection existed because the complaint was based on the defendants’ collective failure to investigate, which they were not legally required to do.

Disposition

The court dismissed the complaint as frivolous and for failing to state a claim upon which relief could be granted. It stated that the complaint was not cognizable under § 1983. The court certified that any appeal in which Adams sought to proceed without paying filing fees would not be taken in good faith, terminated all pending motions, and directed the Clerk to close the file. The opinion does not state that the dismissal was with or without prejudice.