Scarlett v. Alemzadeh
- Lucy Koh
- 5:19-cv-07466
- U.S. District Court · Northern District of California
- 10
In Scarlett v. Alemzadeh, Judge Koh dismissed the complaint without prejudice because it would interfere with an ongoing state criminal case.
Sidney Theodore Scarlett’s federal claims for injunctive and declaratory relief were dismissed without prejudice; Amir Reza Alemzadeh was the defendant. The opinion states that Scarlett could bring suit after his California criminal case, including appeals, ended.
What happened
In Scarlett v. Alemzadeh, Sidney Theodore Scarlett, representing himself, alleged that Amir Reza Alemzadeh violated his rights by refusing to provide a search warrant and exculpatory evidence in Scarlett’s pending California criminal case. Scarlett sought court orders declaring that no valid warrant existed and that the state case could not lawfully continue.
The court applied a rule requiring federal courts generally not to interfere with ongoing state criminal proceedings. It found that all required conditions were met: Scarlett’s state case was still pending, California had important interests in conducting its criminal proceedings, Scarlett could raise his constitutional issues in state court, and the requested federal relief would interfere with that case. The court also found no bad-faith, harassment, or immediate irreparable-injury exception. It denied Scarlett’s motion to strike the defendant’s dismissal motion.
Judge Lucy H. Koh dismissed Scarlett’s claims for injunctive and declaratory relief without prejudice. The court said Scarlett could bring suit after the California criminal case, including any appeals, ended.
The detailed version
- Scarlett v. Alemzadeh · No. 5:19-cv-07466
- Lucy Koh
- July 2, 2020
Background
Sidney Theodore Scarlett filed a self-represented civil-rights complaint against Amir Reza Alemzadeh, whom the opinion identifies as a deputy district attorney in the Santa Clara County District Attorney’s Office. Scarlett alleged that he was unlawfully arrested and that his residence was searched without a warrant in February 2015. Scarlett also alleged that Alemzadeh refused to provide a search warrant and exculpatory evidence in Scarlett’s pending California criminal matter, identified as felony complaint C1503585. Scarlett sought only injunctive and declaratory relief, not money damages.
Scarlett brought his constitutional claims under the federal Administrative Procedure Act (APA), 5 U.S.C. § 702, and invoked the Fourth Amendment and Brady v. Maryland. The defendant argued that the APA applies only to federal agencies and that prosecutorial immunity barred Scarlett’s claims. The court explained that the APA does not provide a basis for reviewing the actions of state, county, or municipal agencies or their employees. Reading Scarlett’s self-represented filing liberally, however, the court construed the complaint as asserting a claim under 42 U.S.C. § 1983 for alleged constitutional violations.
Younger Abstention
The court considered whether Younger abstention applied. Younger abstention is a rule that generally prevents a federal court from interfering with an ongoing state criminal proceeding through injunctive or declaratory relief, absent extraordinary circumstances.
The court found all four required conditions satisfied:
- Ongoing state proceeding: The docket for felony complaint C1503585 was open and showed a hearing scheduled for August
- The defendant also acknowledged that Scarlett’s criminal case was still pending.
- Important state interests: California has an important interest in enforcing its criminal laws and maintaining the integrity of its criminal proceedings.
- Opportunity to raise federal issues: Scarlett could raise his Fourth Amendment and due-process issues in the California criminal case, where the state court could provide appropriate relief. The court also noted that Scarlett was represented by a public defender in that case.
- Interference with the state proceeding: Scarlett’s requested declarations about the warrant and the state court’s authority would have the practical effect of interfering with or stopping the pending criminal case.
The court found no exception to Younger abstention. It concluded that Scarlett’s allegations did not plausibly show bad faith or harassment, and that he had not shown an immediate irreparable injury. The court therefore abstained from deciding the underlying constitutional allegations.
Disposition
The court dismissed Scarlett’s claims for injunctive and declaratory relief without prejudice. It did not decide whether the arrest or search violated the Fourth Amendment, or whether Alemzadeh violated Brady. The court stated that, after the final disposition of the California criminal case, including all appeals, Scarlett could bring suit and seek relief for alleged Fourth Amendment and due-process violations.
The court construed Scarlett’s filing as opposing the defendant’s motion to dismiss and denied Scarlett’s separate motion to strike as unmeritorious. The opinion does not state that the defendant’s motion to dismiss itself was granted or denied.
Read the full 10-page opinion on CourtListener, the free public archive maintained by the Free Law Project.