Robinson v. Alameda County
- Haywood Gilliam
- 4:18-cv-06814
- U.S. District Court · Northern District of California
- 2
In Robinson v. Jackson, Judge Gilliam denied default judgment and extended Robinson’s deadline to oppose Jackson’s summary-judgment motion.
The order affected Robinson’s request for default judgment and his deadline to oppose Jackson’s pending summary-judgment motion. It left the excessive-force claim and summary-judgment motion unresolved.
What happened
In Robinson v. A. Jackson, a prisoner representing himself sued under a federal civil-rights law, alleging that Alameda County deputy Jackson used excessive force while Robinson was held at Santa Rita County Jail. Robinson asked for a judgment because he said Jackson had failed to appear.
The court denied that request because Jackson had appeared through a lawyer, filed a motion, and later filed a waiver of reply. Robinson had not shown that Jackson’s delay had harmed him, and the court emphasized that cases should generally be decided on their merits when reasonably possible.
Judge Haywood S. Gilliam, Jr. also granted Robinson an extension until February 7, 2020, to oppose Jackson’s pending summary-judgment motion, warning that no further extensions would be granted without good cause. The summary-judgment motion itself was not decided in this order.
The detailed version
- Robinson v. Alameda County · No. 4:18-cv-06814
- Haywood Gilliam
- Feb. 3, 2020
Background
Branden Robinson, an inmate at California State Prison–Solano, filed this self-represented civil-rights action under 42 U.S.C. § 1983. He alleged that Alameda County deputy A. Jackson used excessive force against him when Robinson was previously housed as a pretrial detainee at Santa Rita County Jail.
Robinson stated that default had been entered against Jackson for failing to appear and asked the court to enter default judgment. The opinion says that the court issued a summons to Jackson, received an executed summons indicating that W.A. Cohen had been served, and later received Jackson’s appearance through counsel. Jackson requested extensions of time to file a dispositive motion, and the court granted two extensions. Jackson then filed a summary-judgment motion, which remained pending.
Default-judgment request
The court explained that entering default generally establishes a defendant’s liability, but that the court has discretion to deny default judgment. Jackson had appeared and filed a waiver of reply. Robinson did not demonstrate prejudice from Jackson’s delayed filing. Relying on the policy that cases should be decided on their merits when reasonably possible, the court denied Robinson’s request for default judgment.
Extension of time
The court noted that Robinson had not filed an opposition to the pending summary-judgment motion, even though the deadline had passed and the court had already granted two extensions. The court granted Robinson an extension until February 7, 2020, to file his opposition. It stated that no further extensions would be granted without a showing of good cause.
Disposition
The request for default judgment was denied. Robinson was granted additional time to oppose the pending summary-judgment motion. The order terminated docket entry 32; it did not decide the summary-judgment motion or the underlying excessive-force claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.