Dixon v. Director, Office of the District Attorney

Background

Paul Dixon, an inmate housed at Coalinga State Hospital, filed this action without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims against persons who violate constitutional rights while acting under state authority. He sued the unnamed director of the Santa Clara District Attorney’s Office, Santa Clara County District Attorney Dolores A. Carr, supervising deputy district attorney Dana Overstreet, and deputy district attorney Vonda Tracey.

Dixon alleged that the defendants violated the Fourteenth Amendment through malicious abuse of legal process and fraud. He connected those allegations to a 1993 plea bargain, a parole hold, an August 20, 2007 report that allegedly misidentified him as a white male, and later annual reports concerning proceedings under California’s Sexually Violent Predator Act. He also alleged that his contractual rights had been breached. Dixon requested $10 million in damages and punitive damages.

Screening standard

Because Dixon was an inmate suing governmental officials, the court reviewed the complaint under 28 U.S.C. § 1915A. That screening process requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant protected by immunity. The court also stated that a claim under § 1983 requires an alleged violation of a federal constitutional or statutory right by someone acting under state authority.

Court’s analysis

The court concluded that the complaint did not state a recognizable federal constitutional claim. It explained that malicious abuse of process, fraud, and breach of contract are state-law claims. The court also noted that Dixon alleged misconduct by Overstreet but did not allege misconduct by the other named defendants.

Separately, the court held that the defendants were state prosecuting attorneys with absolute immunity under federal law for conduct undertaken while pursuing a criminal prosecution, when acting as advocates for the state and performing work closely connected to the judicial phase of the criminal process. The court concluded that the defendants were immune from Dixon’s claims arising from how they conducted the criminal proceeding connected to his incarceration.

Disposition

The court dismissed the action with prejudice. It entered judgment in favor of the defendants and against Dixon and directed the Clerk to close the case. The opinion does not identify any separate surviving claim.