Khaoone v. Sonoma County Main Adult Detention Facility
- James Donato
- 3:22-cv-04065
- U.S. District Court · Northern District of California
- 3
In Khaoone v. Sonoma County Main Adult Detention Facility, Judge Donato dismissed the amended civil-rights case with prejudice as untimely and legally insufficient.
Preston P. Khaoone’s § 1983 civil-rights action was dismissed with prejudice, ending the case against the Sonoma County Main Adult Detention Facility.
What happened
Preston P. Khaoone sued the Sonoma County Main Adult Detention Facility under a federal civil-rights law, representing himself. He alleged that in 2009 he was improperly placed in administrative segregation for more than six months.
The court said the claim was filed too late. Khaoone argued that he did not know about the filing deadline, but the court found that this did not extend the deadline and that the amended complaint still did not state a claim. The court concluded that further amendment would not fix the problems.
In Khaoone v. Sonoma County Main Adult Detention Facility, Judge James Donato dismissed the case with prejudice, denied further amendment, and directed the clerk to close the case.
The detailed version
- Khaoone v. Sonoma County Main Adult Detention Facility · No. 3:22-cv-04065
- James Donato
- Oct. 28, 2022
Background
Preston P. Khaoone, a state prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against the Sonoma County Main Adult Detention Facility. The court had dismissed his original complaint but allowed him to amend it. Khaoone then filed an amended complaint.
Khaoone alleged that he was improperly moved to administrative segregation at the Sonoma County Main Jail in 2009 and held there for more than six months. The court had previously directed him to provide more information about the filing deadline and about whether the segregation conditions created a protected liberty interest because they imposed an unusually severe hardship or extended his stay at the facility.
Court’s Analysis
The court conducted the required preliminary screening of a prisoner’s complaint against a governmental entity. At this stage, the court must dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also explained that a claim under § 1983 requires an alleged violation of a federal right by someone acting under state law.
The court applied California’s two-year statute of limitations for personal-injury claims to the § 1983 allegations. It also discussed California’s tolling rule for imprisonment, which can delay the deadline for a maximum of two years under the circumstances described in the opinion. The court had previously informed Khaoone that, even assuming four years of tolling, his action was untimely by many years.
Khaoone’s amended complaint addressed the issues identified by the court, but the court found that he still failed to state a claim for relief. His argument that he did not know he had only a limited time to file was insufficient to toll the limitations period under state law. Because the deficiencies could not be cured by another amendment, the court ordered dismissal without allowing further amendment.
Disposition
The court dismissed the action with prejudice, directed the clerk to close the case, and entered the order on October 28, 2022. Judge James Donato signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.