Harris v. Bullard

Background

Zackary T. Harris, an inmate at Lake County Jail, filed this lawsuit without a lawyer under 42 U.S.C. § 1983, a law allowing claims against people acting under state law for violating federal rights. The court reviewed the complaint under 28 U.S.C. § 1915A, which requires early screening of a prisoner’s lawsuit against a government entity or officer.

Harris’s complaint described events from August 2018 through August 2019. It asserted claims concerning his arrests, alleged excessive force, searches and seizures, alleged false arrest and incarceration, state-court proceedings, alleged conspiracies, emotional distress, assault and battery, and jail medical care and other conditions. The complaint named numerous individuals and entities, including law-enforcement officers, public defenders, prosecutors, a judge, jail personnel, the State of California Department of Fish and Wildlife, the County of Lake, and Lake County Jail. Harris sought $5 million in compensatory damages, release from prison, and other damages.

Harris also requested temporary restraints concerning Lake County Jail Sergeant Broussard. He asked the court to require Broussard to provide a six-month trust-account statement and to remove Broussard from supervising Harris’s status as a self-represented litigant because Harris claimed Broussard was denying him legal copies and materials.

Reasons for dismissing the complaint

The court held that claims challenging the state-court proceedings were barred by the Rooker-Feldman doctrine. That doctrine prevents a federal district court from acting as an appeal court reviewing a state-court judgment. The court also explained that a challenge to Harris’s conviction could not be brought through this § 1983 action; depending on the grounds, it might instead be raised in a petition under 28 U.S.C. § 2254, the federal procedure for a person in state custody to challenge a state conviction.

The court therefore dismissed claims challenging the state-court proceedings without leave to amend. It dismissed claims challenging Harris’s conviction without prejudice to seeking relief in a petition for a writ of habeas corpus. The clerk was directed to send Harris two blank habeas-petition forms.

The court also found that the complaint improperly combined unrelated claims and defendants. It gave examples including alleged unlawful arrest and search claims against police officers and later denial of dental care by jail officials. Under Federal Rule of Civil Procedure 20, defendants may be joined only when the claims arise from the same transaction or related series of events and involve a common legal or factual question.

The court further found that the complaint did not clearly connect each defendant to a specific constitutional violation. It instructed Harris that any amended complaint must identify the constitutional right involved, explain what each defendant did or failed to do and when, and explain how that conduct caused injury. The amended complaint could not include claims challenging the state-court proceedings.

Temporary-restraint requests

The court denied as moot Harris’s request for a temporary restraining order requiring Broussard to provide a six-month trust-account statement because Harris’s financial summary was sufficient to complete his application to proceed without paying the filing fee.

The court denied Harris’s request to remove Broussard from supervising his self-represented status. The court found that Harris had not shown immediate and irreparable harm, noting that he had obtained materials needed to litigate and had filed several pleadings. The court also explained that injunctive relief must relate to claims in the operative complaint, and there was no operative complaint because Harris had been given an opportunity to amend. It was also unclear whether Broussard would be named in the amended complaint.

Disposition

The court dismissed the remainder of the complaint with leave to amend. Harris was ordered to file a complete amended complaint within 28 days. The order stated that failure to do so would result in dismissal of the action without further notice. The order terminated the motion for temporary relief at docket number 6.