Adams v. Kerr

Background

Adrian Adams filed a civil-rights action under 42 U.S.C. § 1983 without a lawyer against Santa Cruz Sheriff Jim Hart; Deputy Sheriffs Daren Kerr, Peter Hansen, and Mark Yanez; district attorneys and assistant district attorneys; public defenders; and a court-appointed attorney. The first complaint appeared to seek money damages for alleged violations during more than nine years of state criminal cases.

A magistrate judge granted Adams permission to proceed without paying the filing fee but found that the initial complaint did not provide facts about specific acts or omissions by identified people. The court allowed Adams to amend. Adams then filed a First Amended Complaint. It named some defendants in the body but included additional defendants in the caption, and the court found the pleading difficult to understand.

The amended complaint appeared to allege that Adams's rights were violated during several state criminal prosecutions. It referred to due-process, constitutional, disclosure, attorney-hearing, victims', and legal-representation rights. The complaint alleged, among other things, that Deputy Sheriff Kerr planted drugs on Adams, attended and recorded a hearing concerning Adams's request to replace appointed counsel, and that sheriff's deputies lied during that hearing.

The court also examined whether one state criminal case was still active. Adams asserted that the case showed federal violations, while an email attached to his response stated that the prosecutor had declined to file charges and that the case was dismissed in 2018. The court noted that the state court's online docket still listed the case as active, but said the complaint was subject to dismissal even assuming the docket was incorrect.

Court's Analysis

The court considered the rule from Heck v. Humphrey. Under that rule, a person generally cannot use § 1983 to obtain damages for constitutional violations when proving the claim would necessarily show that a criminal conviction or sentence was unlawful, unless that conviction or sentence had already been reversed, invalidated, or called into question by a court order granting a writ of habeas corpus.

The court said Adams appeared to ask it to find that his rights were violated during his state prosecutions. Such a finding could undermine the validity of his criminal convictions. But Adams did not identify which criminal case involved each alleged violation. The court therefore could not determine whether the prosecutions resulted in convictions or whether any convictions had been reversed, invalidated, or otherwise called into question.

The court concluded that Adams's claims were barred as currently pleaded and dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6), which concerns whether a complaint states a legally sufficient claim. The court granted Adams leave to amend because it found that amendment would not be futile, unfairly prejudice the defendants, cause undue delay, or reflect bad faith.

Disposition

The court DISMISSED the complaint WITHOUT PREJUDICE. Adams was given 30 days to file an amended complaint addressing the identified deficiencies by stating which criminal cases involved each alleged violation, whether those cases resulted in convictions, and whether any convictions had been reversed, invalidated, or called into question by a court-issued writ of habeas corpus. The order stated that failure to amend, or failure to cure the deficiencies, would result in dismissal of deficient claims with prejudice. The court also continued the case-management conference to September 22, 2021.

The opinion is signed by United States District Judge Lucy H. Koh.