Clark v. Board of Supervisors for Marin County
- Jacquelyn Corley
- 3:22-cv-06173
- U.S. District Court · Northern District of California
- 3
In Clark v. Board of Supervisors, Judge Corley dismissed Loureece Stone Clark’s civil-rights complaint as incomprehensible and frivolous, without leave to amend.
Loureece Stone Clark and the Board of Supervisors for Marin County.
What happened
In Loureece Stone Clark v. Board of Supervisors for Marin County, Clark, a detainee at Napa State Hospital who was not represented by a lawyer, filed a civil-rights complaint under federal law. The complaint alleged that the Board failed to accept and pay “just compensation” and failed to provide a verified response, but it did not explain the underlying events or obligations.
The court screened the complaint and found that the claim was incomprehensible and therefore frivolous. The court said it could not identify what the Board allegedly failed to do, what terms applied, or how the legal doctrines Clark cited related to the case. The case was dismissed without leave to amend because the court could not see how the claim could be corrected. The court also denied as unnecessary a motion notifying the court that the matter was under submission.
Judge Jacquelyn Corley ordered the Clerk to enter judgment and close the file.
The detailed version
- Clark v. Board of Supervisors for Marin County · No. 3:22-cv-06173
- Jacquelyn Corley
- Apr. 17, 2023
Background
Loureece Stone Clark, a detainee at Napa State Hospital, filed the complaint without an attorney against the Board of Supervisors for Marin County. The complaint was brought under 42 U.S.C. § 1983, a federal law allowing claims for violations of federal rights by someone acting under state law. The court separately granted Clark permission to proceed without paying the filing fee.
The complaint asserted that the respondents’ alleged “willful failure of non-acceptance and non-payment of just compensation in honor” showed bad faith and placed them in default. It also alleged that their failure to provide a verified response amounted to a failure to act in good faith, agreement to unspecified terms and conditions, and completion of an administrative process. The complaint then stated that the matter was barred or controlled by prior legal principles.
Screening and Analysis
Because Clark was a detainee suing a governmental entity, the court was required to conduct an initial screening under 28 U.S.C. § 1915A. That law requires dismissal of a complaint that is frivolous, malicious, fails to state a claim, or seeks money from a defendant protected from that relief. The court also noted that filings by people without attorneys must be read liberally, but they still must provide enough factual content to make a plausible claim.
The court determined that Clark had made the same claim in an earlier related proceeding. Relying on its explanation in that earlier proceeding, the court found the claim incomprehensible and therefore frivolous. It could not determine what the Board allegedly failed to file, what it supposedly failed to do in good faith, what terms or conditions applied, or what administrative process had been completed. The court also concluded that the claim could not be corrected through amendment.
Disposition
The case was dismissed without leave to amend. The court also denied the motion notifying the court that the matter was under submission because it was unnecessary. The Clerk was directed to enter judgment and close the file.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.