Cardenas v. California
- Charles Breyer
- 3:20-cv-07538
- U.S. District Court · Northern District of California
- 1
In Cardenas v. California, Judge Breyer dismissed Danny Cardenas’s amended civil-rights complaint with prejudice because it challenged private conduct.
Danny Cardenas’s case was dismissed with prejudice. The allegations concerned Crystal Ann Cardenas, whom the opinion describes as a private individual; the case caption listed California as the defendant.
What happened
In Cardenas v. California, Danny Cardenas filed a prisoner complaint under a federal civil-rights law. The court previously found his complaint unclear and allowed him to file a shorter, clearer amended complaint.
Cardenas’s amended filing identified Crystal Ann Cardenas, a private individual, and accused her of falsely claiming that he touched her three-year-old child. The court explained that private conduct, even if wrongful, is not covered by that civil-rights law.
Judge Charles R. Breyer dismissed the action with prejudice because the amended complaint did not state a claim for relief. The clerk was directed to close the case and terminate pending motions as moot.
The detailed version
- Cardenas v. California · No. 3:20-cv-07538
- Charles Breyer
- Mar. 11, 2021
Background
Danny Cardenas filed a prisoner complaint under 42 U.S.C. § 1983. On February 2, 2021, the court dismissed the complaint as confusing and allowed him to amend it. The court instructed him to state clearly who was being sued, what relief he sought, and the legal theory for his claims. It also explained that a private individual generally does not act under color of state law, which is an essential requirement for a § 1983 claim.
On February 18, 2021, Cardenas filed an amended complaint that the clerk docketed as a letter. The filing identified “Crystal Ann Cardenas,” a private individual, and alleged that she falsely accused him of touching her three-year-old child.
Ruling
The court held that purely private conduct is not covered by § 1983. Because the allegations concerned a private individual and did not state a claim for relief under that statute, the court dismissed the action with prejudice under 28 U.S.C. § 1915A(b). The clerk was directed to close the file and terminate all pending motions as moot. Judge Charles R. Breyer signed the order.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.