Hill v. Tyler
- Yvonne Rogers
- 4:20-cv-03156
- U.S. District Court · Northern District of California
- 3
In Hill v. Tyler, Judge Rogers partly granted and partly denied Hill’s motion, requiring proper civil-rights and fee-waiver forms before the case could proceed.
Cymeyon Hill, who must submit the required forms and documentation to pursue the case; Dr. Tyler, whose name was corrected on the docket. The court denied Hill’s request to initiate a federal criminal complaint.
What happened
In Hill v. Tyler, Cymeyon Hill filed what he called a criminal complaint about conditions at Salinas Valley State Prison. The court treated the allegations as potentially belonging in a civil-rights case instead.
Hill asked to correct Dr. Tyler’s name and to receive forms for filing a federal criminal complaint. The court corrected the name but ruled that Hill could not ask this court to prosecute someone else because private citizens have no legally recognized interest in another person’s prosecution.
Judge Rogers granted the motion in part and denied it in part. Hill was given 28 days to submit the proper civil-rights complaint and a non-prisoner application to proceed without paying the filing fee; failing to do so would result in dismissal without prejudice.
The detailed version
- Hill v. Tyler · No. 4:20-cv-03156
- Yvonne Rogers
- July 31, 2020
Background
Cymeyon Hill, identified as a civil detainee, opened this case by filing a document titled “Criminal Complaint” concerning conditions at Salinas Valley State Prison. The case had been opened as a civil-rights action under 42 U.S.C. § 1983, a federal law that allows claims against certain government officials for violating constitutional rights. The Clerk notified Hill that he had not used the required civil-rights complaint form or submitted an application to proceed without paying the filing fee.
Hill then filed a “Motion to Correct Name and to Pursue Criminal Complaint.” The docket had initially listed Defendant Tyler’s name as “Dr. Tylek,” and Hill stated that the correct spelling was “Dr. Tyler.” He also asked for the proper form and instructions to file a federal criminal complaint.
Court’s analysis
The court granted Hill’s request to correct the spelling of Defendant Tyler’s name. It denied his request to file a criminal complaint, explaining that a private citizen does not have a legally recognized interest in whether another person is prosecuted.
The court stated that Hill’s allegations about confinement conditions appeared more appropriate for a civil-rights action under § 1983. It directed Hill to use the correct civil-rights complaint form if he wished to pursue those claims.
The court also determined that Hill was not a “prisoner” under the Prison Litigation Reform Act because the opinion identified him as a civil detainee rather than someone detained because of a criminal accusation, conviction, or sentence. As a result, the prisoner-specific filing-fee requirements did not apply. Hill still had to submit the non-prisoner application required for a person seeking permission to proceed without paying the filing fee.
Order and effect
The court granted in part and denied in part Hill’s motion. It ordered Hill to complete and file the civil-rights complaint form and the non-prisoner fee application, along with any required documentation, within 28 days of the order. If he did not do so, the action would be dismissed without prejudice. The Clerk was directed to send Hill the forms, and the order terminated Docket No. 4. Judge Yvonne Gonzalez Rogers did not decide the underlying confinement claims in this order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.