Leon v. The Office of the County Council for the County of Santa Clara

Background

Joseph R. Leon, a pretrial detainee at the Santa Clara County Jail, filed a self-represented complaint under 42 U.S.C. § 1983. He challenged decisions made by three Santa Clara County Superior Court judges in connection with his ongoing state criminal proceedings and pretrial detention, including decisions about bail and locating and interviewing witnesses. He also challenged the medical care available at the jail. He sought damages and an injunction.

In an October 22, 2021 screening order, the court dismissed the claims against the state judges because judges are generally immune from damages for acts performed in their judicial roles, and the statutory exception for injunctive relief did not apply. The court gave Leon limited permission to amend to try to state a § 1983 claim against jail officials for inadequate medical care under the Fourteenth Amendment. The court also explained that challenges to bail and other matters connected to the ongoing state criminal proceedings would have to be brought, if appropriate, in a new and separate petition challenging custody, subject to applicable requirements.

Amended Complaint and Ruling

Leon timely filed a first amended complaint. He again alleged denial of bail and interference with his ability to represent himself in the ongoing state criminal proceedings. The court ruled that those challenges could not be pursued in this § 1983 action. As to medical care, Leon alleged only, in conclusory terms, denial of “proper medical treatment and wellness health for [a]ll Santa Clara County inmates.” The court had previously instructed him to provide specific facts addressing the officials’ decisions, the substantial risk of serious harm, the failure to take reasonable measures, and resulting injury, but he did not do so.

Judge Charles R. Breyer dismissed the first amended complaint under 28 U.S.C. § 1915A(b) for failure to state a claim on which relief could be granted, without further leave to amend. The opinion does not state that the court decided the underlying medical-care allegations on their merits; it ruled that the amended pleading did not state a legally cognizable claim.