Jenkins v. Garcia
- William Alsup
- 3:20-cv-04420
- U.S. District Court · Northern District of California
- 3
In Jenkins v. Garcia, Judge Alsup dismissed Robert Lee Jenkins’s civil-rights complaint because it did not state a due-process claim.
Robert Lee Jenkins’s § 1983 due-process claim against the named prison officials was dismissed. The order also stated that any possible refund should be sought from the federal court that received the payments.
What happened
In Jenkins v. Garcia, Robert Lee Jenkins, a California prisoner representing himself, sued prison officials under a federal civil-rights law. He claimed they improperly sent money from his prison trust account to the federal court for partial filing fees in several cases.
The court concluded that the alleged withdrawals did not violate due process because they were made under federal court orders, not state law. The court also noted that California provides a remedy for unauthorized property losses and that the claimed damages were limited by a federal law because Jenkins alleged no physical injury.
The court dismissed the case for failure to state a legally valid claim, ordered the clerk to enter judgment and close the file, and granted permission to proceed without paying the full filing fee in a separate order. Judge William Alsup issued the order.
The detailed version
- Jenkins v. Garcia · No. 3:20-cv-04420
- William Alsup
- Nov. 19, 2020
Background
Robert Lee Jenkins, a California prisoner representing himself, sued G. Garcia, S. Herrera, S. Salas, and J. Vernon under 42 U.S.C. § 1983. He alleged that prison officials improperly withdrew money from his trust account and sent it to the federal court as initial partial filing-fee payments in several of his civil-rights cases. He claimed that the withdrawals violated his right to due process and sought $25,000 in damages.
Screening standard
Because Jenkins sought permission to proceed without paying the full filing fee, the court screened the complaint under 28 U.S.C. § 1915. The court explained that it must dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. It also stated that a claim under § 1983 requires an alleged violation of a federal right by a person acting under state authority.
Court’s analysis
The court held that Jenkins had not stated a due-process claim. It explained that a random and unauthorized loss of property generally does not support a federal due-process claim when an adequate state remedy is available, and that California provides such a remedy. Jenkins alleged that the withdrawals were not random or unauthorized, but the court stated that the authority for the withdrawals came from federal court orders directing payment of partial filing fees, not from state law. The court found no legal authority establishing that an inmate’s due-process rights are implicated when state officials take property under federal court authority.
The court stated that, if the federal court orders did not authorize the withdrawals, Jenkins’s possible remedy was to seek a refund from the federal court that received the money. The court also noted that Jenkins sought $25,000 even though less than $200 had been disbursed. Under the Prison Litigation Reform Act, the court said, he could not recover damages for emotional distress without a physical injury. Any compensatory damages or refund for overpayments would have to be sought from the federal court to which the funds were paid.
Disposition
The court dismissed the case for failure to state a cognizable claim for relief. It directed the clerk to enter judgment and close the file. The court granted permission to proceed without paying the full filing fee in a separate order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.