Leon v. Geffon

Background

Joseph R. Leon, identified in the caption as DUX708, was a pretrial detainee at the Santa Clara County Jail. Proceeding without a lawyer, he filed a complaint under 42 U.S.C. § 1983 against Santa Clara County Superior Court Judge Eric S. Geffon, Deputy District Attorney Vicki Gemetti, and other defendants. He challenged the bail consideration hearing and the $1,500,000 bail amount set for him.

Leon alleged that the judge and prosecutor denied him due process and equal protection by, among other things, failing to make findings and inquiries about his ability to pay bail and about less restrictive release conditions. He also alleged that the bail amount violated the Eighth Amendment’s protection against excessive bail. He sought $100 for each day he had been jailed or release, including release on his own recognizance or after posting a lower bail amount. He also asked to proceed without paying filing fees.

Court’s analysis

The court screened the complaint under 28 U.S.C. § 1915A, which requires federal courts to review prisoner complaints against government entities or officials. The court must dismiss a complaint that is frivolous, malicious, fails to state a claim, or seeks money from a defendant protected from such relief. The court also explained that filings by people without lawyers must be read liberally.

The court held that, to the extent Leon sought release from pretrial confinement by being released on his own recognizance or posting bail, his exclusive remedy was a petition for a writ of habeas corpus under 28 U.S.C. § 2241. The court stated that he must first exhaust state judicial remedies. The court also held that damages were unavailable against Judge Geffon because judges have absolute immunity for actions performed in their judicial capacity. It further held that the prosecutor was absolutely immune from damages for conduct undertaken as the state’s advocate and closely connected to the criminal proceeding.

Disposition

The complaint was DISMISSED under 28 U.S.C. § 1915A(b) for failure to state a claim upon which relief may be granted. The dismissal was without prejudice to plaintiff filing a petition for a writ of habeas corpus under 28 U.S.C. § 2241 after exhausting state judicial remedies. The court separately DENIED Leon’s application to proceed without paying filing fees, based solely on his trust-account statement, which reported a balance of $2,647.63. Judge Charles R. Breyer signed the order on March 22, 2021.