Coleman v. Boessenecker

Background

Wendell Coleman sued Mark Boessenecker and 31 other Napa County employees and officials. He asserted claims under the Racketeer Influenced and Corrupt Organizations Act, a federal law commonly known as RICO. His amended complaint listed grievances involving Napa County judges, district attorneys, public defenders, law-enforcement personnel, corrections officers and staff, probation officers, and court contractors. The alleged misconduct included conspiracy, obstruction of justice, threats, fabrication of evidence, kidnapping, false imprisonment, police misconduct, destruction of legal documents, malicious prosecution, false arrest, and abuse of power.

Coleman requested injunctions that would suspend proceedings in Napa County, nullify restraining orders involving Estelle Coleman, suspend the powers of the Napa police and sheriff’s departments, and recognize a claimed basis for removing officials from office. He also sought $700 million from various public entities and $1 million from each defendant.

Screening standard

The court had previously granted Coleman permission to proceed without paying the filing fee. Federal law requires the court to dismiss an action filed under that status if it is frivolous or malicious, fails to state a claim for relief, or seeks money from a defendant immune from such relief. The court applied the same basic standard used for a motion to dismiss for failure to state a claim: the complaint must provide enough factual content to make the requested relief plausible, rather than relying on labels, conclusions, or unsupported assertions.

Court’s analysis

The court said it could not discern a plausible claim for relief because the complaint did not provide a plain statement of facts and instead presented a broad list of grievances arising from multiple years and separate interactions and proceedings. The court also said the complaint appeared frivolous to the extent it alleged a far-reaching RICO conspiracy and sought to suspend the powers of the Napa County court system and police department.

Because the complaint failed, the court concluded that Coleman’s request for an immediate hearing and injunction and his revised injunction request failed as well. The court separately held that the federal Anti-Injunction Act barred the requested preliminary relief. That law generally prevents a federal court from enjoining state-court proceedings unless one of the statute’s listed exceptions applies, and the court found no factual basis showing that an exception applied here.

Disposition

Judge Jacqueline Scott Corley ruled that the complaint failed the required screening. The order allowed Coleman to file an amended complaint within 45 days identifying his claims and stating the supporting facts. The order did not dismiss the action at that time; it stated that failure to amend, or filing an amended complaint that still failed to state plausible claims, would lead the court to issue a Report and Recommendation recommending dismissal. The court stayed defendants’ motion to dismiss, stated that Coleman did not need to respond to that motion, and continued the initial case-management conference to July 30, 2020.