Alexander v. Target Incorporated
- Phyllis Hamilton
- 4:19-cv-07492
- U.S. District Court · Northern District of California
- 4
In Alexander v. Target Incorporated, Judge Hamilton dismissed Alexander’s civil-rights complaint with leave to amend because Target employees were not shown to be state actors.
Robert J. Alexander’s federal civil-rights case was dismissed at the initial screening stage, but he was allowed to file an amended complaint. The Target employees and the police department remained named as defendants in the case at this stage.
What happened
In Alexander v. Target Incorporated, Robert J. Alexander, a detainee representing himself, brought a civil-rights complaint under 42 U.S.C. § 1983 and was allowed to proceed without paying the filing fee. The court reviewed the complaint before the defendants responded.
Alexander alleged that loss-prevention employees at a Target store tackled and detained him, handcuffed him, did not read him his Miranda rights, denied him an attorney, and denied him access to medication and a restroom. He also named a police department, but the complaint did not allege facts against any individual officer.
The court dismissed the complaint with leave to amend, explaining that the Target employees were private actors and that Alexander had not shown they acted for the government, as required for a federal civil-rights claim under Section 1983. The amended complaint was due January 6, 2020. Judge Phyllis J. Hamilton issued the order.
The detailed version
- Alexander v. Target Incorporated · No. 4:19-cv-07492
- Phyllis Hamilton
- Dec. 4, 2019
Background
Robert J. Alexander, identified as a detainee, filed a complaint without a lawyer under 42 U.S.C. § 1983. He was allowed to proceed without paying the filing fee. The court conducted the preliminary screening required for complaints filed by prisoners seeking relief from governmental entities or officials.
Alexander alleged that he was detained at a Target retail store. According to the complaint, Target loss-prevention staff tackled him, detained and handcuffed him, did not read him his Miranda rights, denied him an attorney, and denied him access to medication and a restroom. He also named a police department as a defendant, but the court found that he made no allegations against any individual police officer.
Legal standard
To state a claim under Section 1983, a plaintiff must allege both that a right secured by the Constitution or federal law was violated and that the violation was committed by a person acting under color of state law. Private conduct generally does not satisfy the state-action requirement. Private conduct may qualify only when there is a sufficiently close connection between the government and the challenged conduct for the conduct to be treated as governmental action.
The court also applied the pleading standard requiring enough factual allegations to give defendants fair notice of the claim and make the requested relief plausible, rather than relying only on labels or legal conclusions. Because Alexander was proceeding without a lawyer, the court was required to read his allegations liberally.
Court’s ruling
The court held that the complaint, as currently pleaded, failed to state a claim under Section 1983. The court said the Target defendants were employees of a retail store, not state actors, and Alexander had not shown that they acted under color of state law. The court noted that he could seek relief in state court but had not stated a claim for relief in federal court.
The complaint was DISMISSED with leave to amend. The amended complaint had to be filed by January 6, 2020, use the required caption and case number, state “AMENDED COMPLAINT” on its first page, and include all claims Alexander wished to pursue because an amended complaint replaces the original complaint. The court warned that failing to file an amended complaint could result in dismissal of the action. Judge Phyllis J. Hamilton also directed Alexander to keep the court informed of any address change and comply with court orders.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.