Alexander-Campos v. Marin-Reyes

Background

Robert J. Alexander-Campos, a detainee proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. The court had allowed him to proceed without paying the filing fee.

Alexander-Campos alleged that an employee at a car dealership attacked him. He also alleged that he was improperly arrested and was being prosecuted by a district attorney’s office that had not turned over evidence favorable to his defense.

Court’s analysis

Because Alexander-Campos was a detainee seeking relief from governmental actors, the court screened the complaint under 28 U.S.C. § 1915A. That screening requires dismissal of claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also applied the requirement that a complaint include enough facts to make the claimed entitlement to relief plausible, rather than relying only on labels or conclusions.

For a claim under 42 U.S.C. § 1983, a plaintiff must allege both a violation of a constitutional or federal-law right and conduct by a person acting under state law. The court concluded that the car-dealership employee was a private citizen and was not acting under state law. It therefore stated that Alexander-Campos could not obtain money damages under § 1983 for that assault, although he might be able to seek relief in state court.

The court also applied the rule that federal courts generally should not interfere with ongoing state criminal prosecutions through injunctions or declarations. It found that Alexander-Campos had not shown the extraordinary circumstances needed for such intervention, including bad faith, harassment, or a plainly unconstitutional statute. Regarding the allegedly withheld favorable evidence, the court told him to speak with his assigned counsel.

Disposition

The court dismissed the action for failure to state a claim. It ordered the clerk to close the case. The opinion did not state that the dismissal was with or without prejudice.