Jackson v. Barberini

Background

Julius Lee Jackson, identified as a state prisoner, filed a civil-rights complaint under 42 U.S.C. § 1983 against Chief Ed Barberini, Officer Phaymany Syvongxay, Sheriff Carlos Bolanos, the San Mateo County Jail, Officer M. Vazquez, the City of San Mateo, the County of San Mateo, and the San Mateo County Sheriff’s Department. The court had granted Jackson permission to proceed without paying the filing fee in a separate order.

Jackson alleged that defendants exposed him to inmates who had tested positive for COVID-19, arrested him on drug charges that were later dropped, planted drugs on him, lied in documents, stalked and threatened him, and helped cause several past convictions and periods of imprisonment. He sought damages for the years he said he had spent incarcerated since 1984.

Screening of the complaint

Because Jackson is a prisoner suing governmental entities and officials, the court screened the complaint under 28 U.S.C. § 1915A. The court explained that it had to dismiss claims that were frivolous, malicious, failed to state a claim, or sought money from an immune defendant. It also explained that a § 1983 claim requires an alleged violation of a federal right by someone acting under state law.

Claims involving convictions

The court applied the rule from Heck v. Humphrey, which generally bars a prisoner from seeking damages under § 1983 when success would necessarily imply that a conviction or sentence is invalid, unless that conviction or sentence has already been reversed, expunged, declared invalid, or set aside through a federal court proceeding. The complaint did not indicate that Jackson’s challenged convictions or sentences had been invalidated. The court therefore dismissed without prejudice his claim for damages for the years he had been incarcerated, because success could imply that his convictions were invalid. The court allowed him to amend by alleging facts showing that the convictions had been invalidated. It also stated that, if he wished to challenge a conviction or sentence directly, he could pursue that type of challenge through a federal petition under 28 U.S.C. § 2254, subject to the requirements identified by the court.

COVID-19 exposure claim

The court treated Jackson’s allegation about exposure to infected inmates as a claim about prison conditions under the Eighth Amendment. It said the allegations were insufficient because the timeline did not make sense: Jackson alleged an April 3, 2022 exposure to inmates who had tested positive on December 21, 2022. He also did not allege that he contracted COVID-19 and suffered physical harm, or identify the individual actions of each defendant or facts showing that each defendant knowingly disregarded a substantial risk of serious harm. The court granted leave to amend this claim with specific supporting facts.

False-arrest claim and joinder

The court said Jackson’s allegations might state a false-arrest claim because an arrest must be supported by probable cause, but it also noted that the rule from Heck may bar claims challenging the validity of an arrest or prosecution. In addition, the court found that the false-arrest allegations did not appear related to the COVID-19 prison-conditions claim. Federal Rules of Civil Procedure 18 and 20 limit when claims and defendants may be joined in one lawsuit. The court gave Jackson leave to show that the false-arrest claim was not barred and that the claims and defendants were properly joined. The same joinder issue could apply to any conviction-related claims that were not barred by Heck.

Disposition

The court ordered that the complaint was DISMISSED with leave to amend. Jackson had 28 days from the filing of the order to file an amended complaint on the court’s form, using the required case caption and case number. The court explained that an amended complaint would replace the original complaint, and claims or defendants omitted from it would no longer be part of the action. The court warned that failure to file a compliant amended complaint within the deadline would result in dismissal of the action with prejudice for failure to state a claim, without further notice.