Turner v. Napa State Hospital
- Edward Chen
- 3:19-cv-00318
- U.S. District Court · Northern District of California
- 3
In Turner v. Napa State Hospital, Judge Chen dismissed Turner’s civil-rights case for failing to state a claim.
Anthony Dewayne Lee Turner and the named defendants: Napa State Hospital, Ed Foulk, “Sacramento Courthouse,” and criminal defense attorney Kenneth Lloyd Rosenfield.
What happened
Anthony Dewayne Lee Turner sued Napa State Hospital and others without a lawyer, claiming that he had been held there against his will from February 4, 1999, through February 29, 2016.
The court had allowed Turner to amend his complaint, but his amended complaint still did not explain why the detention was unlawful, identify the release orders and dates, or explain what each defendant did. It also named a courthouse, which the court said was not a suable legal entity, and relied on an attorney’s alleged insult, which was not a claim under the civil-rights statute.
In Turner v. Napa State Hospital, Judge Edward Chen dismissed the action for failure to state a claim, denied further leave to amend because amendment would be futile, and directed the Clerk to close the file.
The detailed version
- Turner v. Napa State Hospital · No. 3:19-cv-00318
- Edward Chen
- Dec. 18, 2019
Background
Anthony Dewayne Lee Turner, who was incarcerated at the Sacramento County Jail when he filed the action, brought this civil-rights lawsuit without a lawyer under 42 U.S.C. § 1983. He apparently challenged an earlier detention at Napa State Hospital.
The court had previously dismissed Turner’s original complaint with leave to amend. It explained that he needed to provide facts showing why the detention was legally impermissible, including the relevant dates, the date and court of any release order, and the length of any confinement after release. He also needed to connect each defendant to the alleged constitutional violation.
Amended Complaint
Turner’s amended complaint alleged that his constitutional rights were violated because he was held against his will at Napa State Hospital from February 4, 1999, until February 29, 2016. It did not identify when he was ordered released, which court issued any release order, or how long he remained confined afterward. It also did not explain what any defendant did or failed to do that caused a constitutional violation.
The amended complaint listed Ed Foulk, identified as Napa State Hospital’s executive director; “Sacramento Courthouse”; and criminal defense attorney Kenneth Lloyd Rosenfield. The court stated that the courthouse was a building rather than a legal entity capable of being sued, and that Turner alleged the courthouse did nothing to violate his rights. The court also ruled that the attorney’s alleged insulting comment was not actionable under § 1983. It explained that verbal harassment and abuse, without more, do not state a claim under that statute, even assuming the attorney was a state actor.
Ruling
The court held that the amended complaint failed to state a claim for excessive detention or any other claim upon which relief could be granted. Judge Edward Chen dismissed the action for failure to state a claim. The court did not grant further leave to amend, finding that amendment would be futile because Turner had already been told what facts were required and had not provided them. The Clerk was directed to close the file.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.