Clark v. Brown

Background

Alphonso Ramon Clark, who was housed at Napa State Hospital, filed this case without a lawyer under 42 U.S.C. § 1983. That statute allows a person to seek relief for the violation of a federal constitutional or statutory right by someone acting under state law. Clark sued Dr. Molly Brown, Dr. Elizabeth Cale, Dr. Lynnette Suarez, and Heather Tegeler, whom the complaint identified as medical or mental-health professionals at the Golden Gate Conditional Release Program. The court noted that Clark’s request to proceed without paying the filing fee would be addressed separately.

Clark alleged that Dr. Brown gave false testimony at his March 2018 hearing by saying he was not taking his medication, which Clark said cost him his freedom. He alleged that Dr. Cale questioned him in an interrogating manner during a January 5, 2018, meeting about a roommate’s claim that Clark was keeping him awake. He alleged that Dr. Suarez called police on January 6, 2018, saying that Clark was agitated and showing signs of paranoia; police then arrested him, although their report did not note those behaviors. Clark also alleged that, while he was in county jail, Tegeler made a case decision even though she was not licensed. He sought damages and asked that the defendants not work in the medical field again.

Screening and pleading deficiencies

Because Clark was a prisoner seeking relief from governmental actors, the court conducted the preliminary review required by 28 U.S.C. § 1915A. The court had to identify claims that were frivolous, failed to state a claim on which relief could be granted, or sought money from an immune defendant. It also said that complaints filed without a lawyer must be read liberally.

The court assumed, for purposes of its analysis, that the Golden Gate Conditional Release Program staff members were state actors. It nevertheless concluded that Clark did not satisfy the requirement of alleging a violation of a constitutional or federal right. The court found no indication that the questioning about his roommate, the call to police based on his concerning behavior, or the allegedly unlicensed decision deprived him of a constitutional right. As to Dr. Brown, the court stated that even if her conduct resulted in unlawful confinement, a challenge to the lawfulness of confinement had to be brought in a separate petition challenging the confinement rather than in a civil-rights complaint. The opinion stated that such a petition could be filed after state remedies were exhausted if Clark was challenging the constitutionality of state civil-commitment proceedings.

The court also held that the complaint improperly joined claims and defendants under Federal Rules of Civil Procedure 18(a) and 20(a). Rule 18(a) governs joining multiple claims against one opposing party. Rule 20(a) permits multiple defendants in one action only when the claims arise from the same transaction or occurrence, or series of transactions or occurrences, and involve a common question of law or fact. The court found that the claims were against different defendants and did not arise from the same transaction or occurrence.

Disposition

The court DISMISSED the complaint with leave to amend. It gave Clark one opportunity to file an amended complaint with sufficient factual allegations and claims that complied with Rules 18(a) and 20(a). The amended complaint had to use the caption and case number in the order and include the words “AMENDED COMPLAINT” on its first page. The court explained that an amended complaint would replace the original complaint, so claims and defendants omitted from it would no longer be part of the case.

The order required the amended complaint within 28 days of the order’s filing. It stated that failure to respond as required would result in dismissal with prejudice of the action for failure to state a claim, without further notice. The present order itself dismissed the complaint with leave to amend; it did not impose that later dismissal with prejudice at that time.