Adams v. Head of CNA Financial, Orange County Branch

Background

Rineson C. Adams, a state prisoner representing himself, filed a civil-rights complaint under 42 U.S.C. § 1983. The defendant was identified as the head of CNA Financial’s Orange County branch. Adams alleged that this person seized his companies and “empire” before Adams’s eighteenth birthday. Adams also stated that he filed a claim in small-claims court in 2005–2007 and won. He sought review of the small-claims cases and an order arranging a transaction to obtain his companies.

Screening standard

Because Adams was a prisoner seeking relief under Section 1983, the court conducted the required preliminary screening under 28 U.S.C. § 1915A. The court explained that it had to dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. It also applied the rule that a complaint must provide enough factual matter to make the requested relief plausible. To state a Section 1983 claim, a plaintiff must allege both a violation of a right secured by the Constitution or federal law and conduct by a person acting under color of state law.

Ruling

The court concluded that Adams’s allegations were frivolous and failed to state a claim under Section 1983. The court also noted that Adams was not incarcerated in this district and that the events did not occur here. It determined that no amendment could cure the complaint’s deficiencies and dismissed the action without leave to amend. The court stated that any action Adams sought to bring apart from Section 1983 should be filed in the appropriate district.

The court dismissed the complaint for failure to state a claim, denied Adams’s motions to proceed without paying filing fees, and requested that the clerk close the case. Judge James Donato ordered the dismissal on November 4, 2021.