Clark v. Board of Equalization

Background

Loureece Stone Clark, a detainee at Napa State Hospital, filed the complaint without an attorney under 42 U.S.C. § 1983. That statute allows a person to sue for a violation of federal rights by someone acting under state authority. The defendant was the California State Board of Equalization. The court noted that Clark had filed 12 cases in that court during an approximately six-month period. A separate order allowed Clark to proceed without paying the filing fee.

Screening standard

Because the complaint sought relief from a governmental entity, the court screened it under 28 U.S.C. § 1915A. The court was required to identify valid claims or dismiss claims that were frivolous, failed to state a claim, or sought money from an immune defendant. The court also explained that filings by people without lawyers must be read generously, but they still must provide enough factual information to make a claim understandable and plausible.

Court’s analysis

The complaint’s entire claim stated that the Board had willfully failed to accept and pay “just compensation in honor,” had acted in bad faith, and had failed to provide a “verified response.” It also referred to an administrative process, res judicata, and stare decisis without explaining what those terms had to do with the case.

The court held that the claim was incomprehensible and therefore frivolous. It also held that the California State Board of Equalization was a state agency protected from suit in federal court by the Eleventh Amendment. The court concluded that the complaint could not be fixed by amendment.

Disposition

The case was dismissed without leave to amend. The Clerk was directed to enter judgment and close the file.