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N.D. Cal.Procedural orderFiled Dec. 8, 2021

Patterson v. Matteson

Judge
Beth Freeman
Docket
5:21-cv-07391
Court
U.S. District Court · Northern District of California
Pages
5
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Patterson v. Matteson, Judge Freeman allowed Patterson’s equal-protection claim past screening and ordered service on Matteson.

Who this affects

Norman Eugene Patterson’s equal-protection claim proceeds past initial screening against G. Matteson; the order also sets service and litigation deadlines for both parties.

What happened

In Patterson v. Matteson, Norman Eugene Patterson, a state prisoner, alleged that California Penal Code § 3501(h) violates his Fourteenth Amendment equal-protection rights. He brought the claim under a federal civil-rights law that allows suits against state officials.

The court found that, when read generously, Patterson’s allegations appeared to state a constitutional claim. It ordered that G. Matteson, identified as the warden of California State Prison, Solano, be served. The court also set deadlines for a possible defense motion, Patterson’s response, discovery, and other case procedures. Patterson’s request to proceed without paying the filing fee was granted in a separate order.

This was an initial screening and service order, not a final decision on whether Patterson’s claim is correct. Judge Beth Freeman ordered the case to proceed against Matteson at this stage.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Patterson v. Matteson · No. 5:21-cv-07391
Judge
Beth Freeman
Date
Dec. 8, 2021

Background

Norman Eugene Patterson, identified in the opinion as a state prisoner incarcerated at California State Prison, Solano, filed a civil-rights action without a lawyer under 42 U.S.C. § 1983. He alleged that California Penal Code § 3501(h) violates his equal-protection rights under the Fourteenth Amendment. The defendant is G. Matteson, identified as the warden of California State Prison, Solano.

Patterson also moved to proceed without paying the filing fee. The opinion states that the court granted that motion in a separate order.

Screening

Because Patterson is a prisoner seeking relief from a government officer, the court was required to conduct an initial screening under 28 U.S.C. § 1915A. At screening, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also stated that allegations filed without a lawyer must be read generously.

Ruling and case status

The court stated that, when read generously, Patterson’s allegations appeared to present a claim that California Penal Code § 3501(h) violates his equal-protection rights. It therefore ordered that G. Matteson be served through the California Department of Corrections and Rehabilitation’s electronic-service process, with service by the United States Marshals Service if necessary.

The order required the defendant to file a motion for summary judgment or another motion that could resolve the case within 60 days after service, unless the defendant informed the court that the case could not be resolved that way. It set deadlines for Patterson’s opposition and any reply, explained the required warnings concerning summary judgment and exhaustion of administrative remedies, and permitted discovery under the Federal Rules of Civil Procedure.

The order did not decide the ultimate merits of Patterson’s equal-protection claim. It was an initial screening and service order allowing the claim to proceed at that stage.

The authoritative version

Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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