Dilnessa v. Social Security Administration
- Jeffrey White
- 4:23-cv-01013
- U.S. District Court · Northern District of California
- 3
In Dilnessa v. Social Security Administration, Judge White dismissed the pro se complaint after finding it incoherent and legally insufficient under prisoner-screening rules.
The dismissal ended Ayalneh A Dilnessa’s Section 1983 case against the Social Security Administration, the Butte County Sheriff’s Department, and the defendant identified in the discussion as the California Department of State Hospitals. The court entered judgment and closed the file.
What happened
Ayalneh A Dilnessa, who was incarcerated at Napa State Hospital, filed a self-represented civil-rights complaint under Section 1983 against the Social Security Administration, the Butte County Sheriff’s Department, and Napa State Hospital.
The court found the complaint incomprehensible and lacking a basis in law or fact. It also explained that Section 1983 does not apply to the federal Social Security Administration, claims involving actions in Butte County belonged in the Eastern District of California, and the California Department of State Hospitals could not be sued for money damages because of state immunity.
The court dismissed the case for failure to state a claim, ordered the clerk to enter judgment, and closed the file. Judge Jeffrey White issued the order on March 9, 2023.
The detailed version
- Dilnessa v. Social Security Administration · No. 4:23-cv-01013
- Jeffrey White
- Mar. 9, 2023
Background
Ayalneh A Dilnessa filed a self-represented civil-rights complaint under 42 U.S.C. § 1983. The complaint named the Social Security Administration, the Butte County Sheriff’s Department, and Napa State Hospital as defendants. The court separately granted permission to proceed without paying filing fees.
Because the plaintiff was incarcerated and sued governmental entities, the court screened the complaint under 28 U.S.C. § 1915A. That screening law requires the court to identify claims that can proceed and dismiss claims that are frivolous, fail to state a claim, or seek money from a defendant protected from such relief. The court also applied the requirement that a complaint provide enough factual information to give defendants fair notice of the claims and their grounds.
Court’s analysis
The court held that the complaint was frivolous because it was incomprehensible and incoherent. It described the complaint as a collection of legal terms arranged in an apparently random and nonsensical order, with factual allegations that had no apparent or explained connection to those terms. The court concluded that the complaint had no basis in law or fact.
The court also identified separate problems with suing the named defendants under Section 1983 for money damages:
- The Social Security Administration is an arm of the federal government and therefore is not a state actor subject to liability under Section 1983. - The court stated that the Butte County Sheriff’s Department can be a state actor, but that claims based on actions taken in Butte County must be brought in the Eastern District of California rather than in this court. - The court referred to the third defendant as the California Department of State Hospitals and held that it was protected from money-damages claims by the Eleventh Amendment because it is a department of California. The court stated that damages claims could be brought against individual Department of State Hospitals employees in their individual capacities, but not against the state department itself.
Disposition
The court dismissed the case for failure to state a claim upon which relief may be granted. It directed the clerk to enter judgment and close the file. Judge Jeffrey White signed the order on March 9, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.