Patterson v. Santa Clara County SET
- Edward Davila
- 5:20-cv-07160
- U.S. District Court · Northern District of California
- 3
In Patterson v. Santa Clara County SET, Judge Davila dismissed Patterson’s federal civil-rights complaint over property loss for failure to state a claim.
The dismissal affected Jeffrey Wade Patterson’s federal property-loss claim against Santa Clara County SET and the other defendants. The court said he must pursue the claim in state court.
What happened
In Patterson v. Santa Clara County SET, Jeffrey Wade Patterson, who was detained at the Santa Clara County Jail and represented himself, sued under federal civil-rights law. He alleged that defendants damaged his residence while executing a felony search warrant and that private burglars and squatters later stole his property.
The court screened the complaint as required in prisoner cases against government entities or employees. It found that Patterson did not allege a violation of a constitutional or federal right because he did not claim that the defendants themselves took his property. The court said that, at most, the allegations described negligence that could support a state-law claim, not a federal civil-rights claim.
Judge Edward J. Davila dismissed the complaint for failure to state a claim for relief, directed Patterson to pursue the claim in state court, and ordered the Clerk to close the file.
The detailed version
- Patterson v. Santa Clara County SET · No. 5:20-cv-07160
- Edward Davila
- Feb. 11, 2021
Background
Jeffrey Wade Patterson, who was detained at the Santa Clara County Jail and proceeded without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against the Santa Clara Police Department for loss of property. He alleged that on September 26, 2019, defendants broke down doors at his residence to execute a felony search warrant. He also alleged that defendants did not show him the warrant when he asked for it.
Patterson sought $35,000 for personal property that he said was stolen by unidentified burglars and squatters after police broke in, disabled alarms and cameras, and disabled locks.
Screening standard
The court explained that it must conduct an initial screening when a prisoner seeks relief from a governmental entity or a government officer or employee. The court must dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant who is immune from such relief. The court also said that pleadings filed without a lawyer must be read liberally.
To state a claim under § 1983, a plaintiff must allege both a violation of a right secured by the Constitution or federal law and conduct by a person acting under state law.
Court’s analysis
The court held that Patterson failed to allege the first required element: a violation of a constitutional or federal right. Patterson did not allege that defendants themselves seized the property, which could have implicated due-process protections. Instead, he alleged that unidentified private individuals stole the property.
The court stated that, at most, defendants may have acted negligently by failing to secure the area after executing the warrant. It concluded that this would amount to tortious conduct actionable under state law, not a claim under § 1983. The court further stated that there was no independent basis for federal jurisdiction and that Patterson must pursue the claim in state court.
Disposition
The court dismissed the complaint for failure to state a claim for relief. It directed Patterson to pursue the claims in state court, ordered the Clerk to close the file, and stated that the motion for permission to proceed without paying the filing fee would be addressed in a separate order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.