Barnes v. Santa Clara County District Attorneys Office
- Yvonne Rogers
- 4:20-cv-02113
- U.S. District Court · Northern District of California
- 4
In Barnes v. Santa Clara County District Attorney’s Office, Judge Rogers allowed a supplemental complaint but dismissed both complaints for failing to state a civil-rights claim.
Antoine Deshawn Barnes’s claims against the Santa Clara County District Attorney’s Office, the Santa Clara County Superior Court, and the presiding judge in Case #2040007 were dismissed. The court granted his request to file a supplemental complaint but dismissed that supplemental complaint as well.
What happened
Antoine Deshawn Barnes, who was in custody at Kings County Jail, filed a self-represented civil-rights lawsuit against the Santa Clara County District Attorney’s Office and the Santa Clara County Superior Court. He claimed that prosecutors conspired to have excessive bail set and sought to add the judge involved in his criminal case as a defendant.
The court allowed Barnes to file the supplemental complaint. After screening the filings, however, the court concluded that the claims could not proceed. It said prosecutors have complete protection from damages for actions taken as advocates in a criminal case, judges have complete protection from damages for judicial acts, and the state court was protected by the Eleventh Amendment.
Judge Yvonne Gonzalez Rogers dismissed the complaint and supplemental complaint for failure to state a claim, without leave to amend. She also certified that an appeal seeking to proceed without paying filing fees would not be taken in good faith, terminated the pending motions as moot, and closed the case.
The detailed version
- Barnes v. Santa Clara County District Attorneys Office · No. 4:20-cv-02113
- Yvonne Rogers
- July 14, 2020
Background
Antoine Deshawn Barnes filed a self-represented civil-rights complaint under 42 U.S.C. § 1983 while he was in custody at Kings County Jail. He named the Santa Clara County District Attorney’s Office and the “Superior Court of San Jose,” identified in the opinion as the Santa Clara County Superior Court. Barnes alleged that the District Attorney’s Office conspired to have excessive bail set.
Barnes also filed a motion asking to add the presiding judge in Case #2040007 as a defendant. The court treated that filing as a request to file a supplemental complaint under Federal Rule of Civil Procedure 15(d). The court granted that request so it could consider the related claim against the judge.
Court’s analysis
The court screened the complaint and supplemental complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner lawsuits against governmental entities or officials and dismiss claims that are frivolous, fail to state a claim, or seek damages from an immune defendant. To state a claim under § 1983, a plaintiff must allege a violation of a federal right by someone acting under state law.
The court held that the claims against the District Attorney’s Office were barred by absolute prosecutorial immunity because the alleged conduct concerning bail was taken by prosecutors as advocates for the state in the criminal case. The court held that the state judge was absolutely immune from damages claims for acts performed in a judicial capacity. It also held that the claims against the Santa Clara County Superior Court were barred by the Eleventh Amendment.
Disposition
The court dismissed the complaint and supplemental complaint for failure to state a claim. The dismissal was without leave to amend because the court found that amendment would be futile. Judge Yvonne Gonzalez Rogers also certified that any appeal seeking to proceed without paying filing fees would not be taken in good faith, directed the clerk to terminate pending motions as moot, and closed the file.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.