Harris v. Director of Corrections
- Susan Illston
- 3:19-cv-03166
- U.S. District Court · Northern District of California
- 2
In Harris v. Director of Corrections, Judge Illston dismissed David D. Harris’s complaint as legally frivolous during prisoner screening.
David D. Harris’s complaint was dismissed, ending this case; the opinion does not identify any further effect on the challenged fine.
What happened
In Harris v. Director of Corrections, David D. Harris, who was incarcerated, filed a self-represented complaint called a “writ of replevin complaint.”
The complaint appeared to challenge a fine imposed as part of his state criminal sentence. Harris alleged that he did not know about the fine at arraignment, and included theories and documents concerning liens, property, bonds, and collateral that the court found difficult to understand.
The court dismissed the complaint as legally frivolous after screening it under the federal prisoner-screening law and directed the clerk to close the file. Judge Susan Illston signed the order.
The detailed version
- Harris v. Director of Corrections · No. 3:19-cv-03166
- Susan Illston
- Dec. 2, 2019
Background
David D. Harris, who was incarcerated at the California Health Care Facility in Stockton, California, filed a self-represented “writ of replevin complaint” against the Director of Corrections. The court reviewed the complaint under 28 U.S.C. § 1915A, which requires preliminary screening of a prisoner’s case seeking relief from a governmental entity or government officer or employee.
The opinion states that the complaint appeared to challenge a fine imposed as part of Harris’s sentence in a state criminal case. Harris alleged that he was unaware of the fine at his arraignment but was held responsible for unpaid fines. The complaint also included theories asserting that Harris was real property, that a lien on that property should be released, and that different collateral should be used in his place as a bond. The attachments included a birth certificate and forms concerning surety, liens, escrow, payment bonds, bid bonds, and performance bonds.
Court’s Analysis
The court explained that it must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek monetary relief from an immune defendant. It also noted that self-represented pleadings must be read liberally, but an incomprehensible claim may be dismissed as frivolous when it lacks an arguable basis in law.
The court found that the complaint “borders on the incomprehensible” and that its allegations made no sense. It concluded that the complaint was legally frivolous because it was based on an indisputably meritless legal theory or lacked a factual basis.
Disposition
The court dismissed the complaint as legally frivolous and directed the clerk to close the file. The order does not state that the dismissal was with or without prejudice. Judge Susan Illston signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.