Manalisay v. Hall
- Vince Chhabria
- 3:22-cv-04701
- U.S. District Court · Northern District of California
- 2
In Manalisay v. Hall, Judge Chhabria dismissed the complaint for failure to state a claim, allowing amendment within 21 days.
James Manalisay’s complaint was dismissed; the action also named Boydine Hall and other defendants. Manalisay was allowed to amend the complaint within 21 days, subject to the stated warning about dismissal with prejudice.
What happened
In James Manalisay v. Boydine Hall, et al., the court reviewed Manalisay’s civil-rights complaint under a federal law governing claims against state officials.
The court said allegations of criminal misconduct generally do not support a civil-rights lawsuit under Section 1983, and a federal statute must provide a private right to sue before it can support such a claim. The court also said Manalisay did not provide enough facts to plausibly show a due-process violation.
Judge Vince Chhabria dismissed the complaint for failure to state a claim but allowed Manalisay to amend it. The court said any amended complaint must be filed within 21 days and warned that, if none is filed, the dismissal will be with prejudice.
The detailed version
- Manalisay v. Hall · No. 3:22-cv-04701
- Vince Chhabria
- Sept. 29, 2022
Background
James Manalisay brought an action under Section 1983. The opinion does not describe the underlying events in detail. The court reviewed the complaint under 28 U.S.C. § 1915(e)(2)(B), which requires dismissal when a qualifying complaint fails to state a claim on which relief may be granted.
Court’s analysis
The court addressed two potential bases for Manalisay’s claims. First, to the extent he relied on alleged criminal misconduct, the court held that violations of criminal laws will rarely provide a basis for a civil lawsuit under Section 1983. The court also stated that a federal statute can support a Section 1983 claim only if that statute creates a private right of action, meaning a right for a person to sue.
Second, to the extent Manalisay alleged due-process violations, the court held that he had not pleaded enough facts to plausibly state a claim.
Disposition
The court dismissed the complaint for failure to state a claim, with leave to amend. Any amended complaint must plainly describe the events in the order they occurred, each defendant’s title and role in those events, and the rights Manalisay believes were violated. The court instructed Manalisay not to assume familiarity with proceedings before other courts or administrative actors. If he does not file an amended complaint within 21 days of the order, the dismissal will be with prejudice. Judge Vince Chhabria signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.