Wilson v. County of Contra Costa

Background

Michael Geary Wilson filed a complaint against more than 200 defendants, including counties, cities, California Superior Courts, law firms, government officials, police officers, attorneys, and judges. The complaint asserted 46 claims under state and federal law. Wilson alleged that the defendants learned about his physical and mental disabilities and then exploited them through various means, including violence, fraud, sham litigation, and extortion. The opinion states that the complaint was 554 pages long and included lengthy transcripts, personal theories, and descriptions of Wilson’s internal thoughts.

Wilson also submitted a declaration seeking to disqualify the judge and, apparently, every judge in the district. He argued that local rules governing response deadlines and electronic filing conflicted with the Federal Rules of Civil Procedure, and that the judge’s acceptance of those rules demonstrated bias or prejudice.

Disqualification motion

The court denied the motion to disqualify. It explained that a disqualification affidavit must identify facts fairly supporting a claim of personal bias or prejudice. Wilson’s declaration was based on his disagreement with local rules and judicial rulings. The court held that neither disagreement was a legally sufficient ground for recusal, meaning removal of the judge from the case.

The court also addressed Wilson’s concerns about filing deadlines. It stated that the Federal Rules of Civil Procedure do not set a specific period for opposing or replying to motions, that the local deadlines therefore did not conflict with those rules, and that other federal rules still provided time to amend and respond. It further stated that, under the applicable general order, self-represented parties did not need to request permission to access the electronic filing system at that time.

Application to proceed without prepaying fees

The court granted Wilson’s application to proceed without prepaying filing fees. It found that his application showed he was unable to pay the fees.

The court noted that it still had a continuing duty to dismiss a complaint that is frivolous or malicious, fails to state a claim, or seeks money from a defendant who is immune from that relief.

Complaint dismissal

The court dismissed the complaint because it did not satisfy Federal Rule of Civil Procedure 8(a), which requires a short and plain statement giving defendants fair notice of the claims and the grounds for them. Even when reading a self-represented plaintiff’s complaint liberally, the court found that Wilson’s pleading was needlessly long, rambling, and confusing.

The court also found that Wilson incorporated broad allegations into his claims for relief and asserted that all defendants were liable for most claims through conspiracy allegations. As a result, it was nearly impossible to determine which alleged act supported a particular claim or which defendant allegedly caused a particular injury.

The court dismissed the complaint and denied leave to amend. It cited Wilson’s prior history in the district and described the complaint’s broad and sprawling approach as hopeless. The opinion does not add the phrases “with prejudice” or “without prejudice” to the dismissal.

Other motion and disposition

A group of defendants had filed two motions asking that Wilson be designated a vexatious litigant, one before Judge Chesney and one in this case. The court stated that only one motion was necessary and would defer to Judge Chesney’s decision based on her experience with Wilson. The court therefore denied the motion filed in this action as moot.

The order states that Wilson’s next step, if he wished to pursue the lawsuit, was to file a timely notice of appeal.