Wilson v. Mount Diablo Unified School District/Special Education Local Plan Area

Background

Michael Geary Wilson alleged that he was an indigent California citizen with disabilities and that he and PARENT-1 had been involved in two civil disputes with Mount Diablo Unified School District/Special Education Local Plan Area. Wilson alleged that attorneys representing Mount Diablo threatened to pursue criminal charges unless he and PARENT-1 released their civil claims. He also alleged that the attorneys representing him in the second dispute forwarded the communications, failed to tell him the threats were illegal, and pressured him to accept them.

Wilson asserted two state-law claims—attempted civil extortion and intentional infliction of emotional distress—and five federal claims: a claim under 42 U.S.C. § 1983, conspiracy claims under 42 U.S.C. § 1985(2) and § 1985(3), a claim under 42 U.S.C. § 1986 for failing to prevent a § 1985 violation, and a municipal-liability claim against Mount Diablo under Monell v. Department of Social Services.

Federal Claims

Defendants argued that Wilson’s federal claims were barred because they duplicated claims from an earlier related case. The court rejected that argument, explaining that the earlier case involved allegations about special-education services, while this case involved alleged threats during later settlement negotiations.

The court dismissed Wilson’s § 1983 claim. It held that the private attorneys and law firms did not act under color of state law merely by representing Mount Diablo. It also found that the two emails Wilson relied on did not contain the threats he attributed to them. Separately, the court found that Wilson had not adequately alleged denial of access to the courts, another First Amendment right, a liberty interest in his reputation, or equal-protection discrimination based on indigence or disability.

The court dismissed the Monell claim because Wilson did not plead facts showing that Mount Diablo had a policy or custom of threatening criminal prosecution in exchange for settling civil cases. It dismissed the § 1985(2) and § 1985(3) claims because Wilson did not allege facts showing a conspiracy or the required discriminatory motivation. The court also dismissed the § 1986 claim because such a claim requires a valid § 1985 claim, which Wilson had not pleaded. The court stated that Wilson might be able to correct some deficiencies and therefore allowed amendment of the federal claims.

State Claims and Disposition

The state claims were before the court only through supplemental jurisdiction, which allows a federal court to hear related state claims. After dismissing the federal claims, the court declined to continue exercising that jurisdiction because the case remained at the pleading stage and no apparent consideration favored retaining the state claims. It dismissed the state claims without prejudice to refiling if Wilson chose to amend his federal claims.

The court’s order stated that defendants’ motions to dismiss, motions to dismiss and strike, and motions to strike were granted in part and denied in part. The motions were granted as to dismissal of the federal claims, which were dismissed with leave to amend; the state claims were dismissed without prejudice; and the motions to strike the state claims were denied as moot. The court also continued the case-management conference from April 3, 2020, to June 26, 2020.