Clark v. Social Security Administration
- Jacquelyn Corley
- 3:23-cv-00967
- U.S. District Court · Northern District of California
- 4
Clark v. Social Security Administration: Judge Corley dismissed the incomprehensible civil-rights complaint without leave to amend after required screening.
Loureece Stone Clark’s civil-rights case against the Social Security Administration, the Marin County Sheriff’s Department, and the California Department of State Hospitals was dismissed without leave to amend.
What happened
In Clark v. Social Security Administration, Loureece Stone Clark, a detainee at Napa State Hospital, sued the Social Security Administration, the Marin County Sheriff’s Department, and the California Department of State Hospitals under a federal civil-rights law. The complaint listed many alleged violations but did not clearly explain what the defendants had done or how those actions violated the law.
The court found the complaint wholly incomprehensible and therefore frivolous. It dismissed the case without leave to amend, meaning Clark was not allowed to file an amended complaint in this case. The clerk was ordered to enter judgment and close the file.
Judge Jacquelyn Corley issued the April 27, 2023 order after screening the complaint. She concluded that the problems could not be cured by amendment.
The detailed version
- Clark v. Social Security Administration · No. 3:23-cv-00967
- Jacquelyn Corley
- Apr. 27, 2023
Background
Loureece Stone Clark, identified in the opinion as a detainee at Napa State Hospital, filed a civil-rights complaint under 42 U.S.C. § 1983 against the Social Security Administration, the Marin County Sheriff’s Department, and the California Department of State Hospitals. The opinion states that Clark filed 12 cases in the court in approximately six months. The court separately granted Clark permission to proceed without paying the filing fee.
Screening standard
Under 28 U.S.C. § 1915A, a federal court must screen a prisoner’s complaint seeking relief from a governmental entity or government officer or employee. The court must identify claims that may proceed or dismiss the complaint, or part of it, if it is frivolous, malicious, fails to state a claim for relief, or seeks money from a defendant protected from that type of relief. To state a claim under § 1983, a plaintiff must allege that a federal constitutional or statutory right was violated by someone acting under state authority.
Court’s analysis
The complaint alleged, among other things, that the defendants refused to provide compensation from a trust fund and violated rights under the Fifth Amendment, the Privacy Act of 1974, the Social Security Act, and other laws. It also referred to unidentified private communications, commercial systems, titles of nobility, and alleged contracts or agreements.
The court held that the claim was wholly incomprehensible and therefore frivolous. It could not determine what Clark meant by several of the complaint’s central phrases. The court also found that the complaint made only conclusory allegations about violations of numerous federal laws and did not identify what the alleged private communications concerned or explain how they violated those laws.
Disposition
The court dismissed the case without leave to amend because it could not discern any way the complaint’s defects could be cured by amendment. The clerk was directed to enter judgment and close the file. Judge Jacquelyn Corley signed the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.