Stuckey v. Trump

Background

Andre Kenneth Stuckey, who was incarcerated at Pelican Bay State Prison, filed this civil-rights action without a lawyer seeking money damages under Bivens v. Six Unknown Named Agents. His amended complaint named the President of the United States, current and former United States Attorneys General, the Federal Bureau of Investigation Director, a supervising special FBI agent, and the Chief of the Department of Justice’s Special Litigation Section.

The court understood the claims to allege that President Donald J. Trump and FBI Director Christopher Wray signed fiscal budgets that reduced funding for Department of Justice accounts, including the FBI. Stuckey appeared to allege that the other defendants failed to investigate alleged civil-rights violations at Pelican Bay State Prison. The court had allowed him to proceed without paying the filing fee.

Court’s analysis

The court screened the complaint under 28 U.S.C. § 1915A, which requires courts to dismiss a prisoner’s complaint, or part of it, if it is frivolous, fails to state a claim, or seeks money from an immune defendant. To state a Bivens claim, a plaintiff must allege that a federal actor violated a constitutional right.

The court concluded that Stuckey had not alleged the deprivation of a constitutional right or a right under federal law. It rejected the claim against Trump and Wray based on signing fiscal budgets because those alleged actions did not amount to official misconduct. It also stated that neither Trump nor Wray had personal involvement in Stuckey’s other claims, so those claims could not support damages against them in their individual capacities.

As to the remaining defendants, the court held that there is no constitutional right to an investigation by government officials. It concluded that allegations that these defendants were required to investigate the alleged violations at Pelican Bay did not state a legally cognizable civil-rights claim. The court further found that the allegations were conclusory, lacked factual support, and were legally frivolous, even under the liberal interpretation given to pleadings filed without a lawyer.

Disposition

The court dismissed the amended complaint under 28 U.S.C. § 1915A(b) for failure to state a claim upon which relief may be granted. It directed the Clerk to terminate pending motions as moot and close the file. Judge Yvonne Gonzalez Rogers signed the order.