Adams v. San Francisco FBI

Background

Henry Desean Adams, identified as a state inmate, filed this pro se civil-rights action under 42 U.S.C. § 1983. The defendants named in the complaint were an unknown FBI Special Agent “in charge”; Contra Costa County Deputy District Attorney Kabu Adodojaji; Sgt. Williams and Deputies Inglestate, Rector, Oathuh, and Hughes of the Contra Costa County Sheriff’s Department; Nurses Jennifer Gonzaga and Mary Bolds; and Doctors Jessica Hamilton and Elizabeth Berryman of the Martinez Detention Facility. Adams sought injunctive relief and damages.

Adams described several separate events: a June 18, 2015 arrest on what he called a canceled and false warrant; an alleged conspiracy involving his identity and family members to purchase properties; allegedly wrong medication in November 2017; threats in 2017 and July 2018; alleged embezzlement of his inheritance; failure to treat sexually transmitted diseases and diabetes; and alleged falsification of medical records.

Screening and Deficiencies

Because Adams was a prisoner suing governmental actors, the court screened the complaint under 28 U.S.C. § 1915A. That screening requires dismissal of claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. To state a § 1983 claim, a plaintiff must allege both a violation of a federal constitutional or statutory right and action under color of state law.

The court held that Adams’s challenge to the allegedly false warrant and arrest could implicate the validity of his later conviction or sentence. Under the rule from Heck v. Humphrey, a prisoner generally cannot recover damages under § 1983 for conduct whose unlawfulness would necessarily invalidate a conviction or sentence unless that conviction or sentence has already been reversed, expunged, declared invalid, or otherwise called into question through the specified legal processes. The court dismissed this part of the complaint with leave to amend so Adams could allege facts showing that success on the arrest claim would not invalidate his conviction or sentence, or show that the conviction or sentence had already been invalidated.

The court also found the conspiracy and inheritance allegations deficient. Conspiracy is not itself a constitutional violation, and the complaint did not provide enough material facts showing what happened or what constitutional right was violated. The court also said it was unclear whether the defendants acted under color of state law in connection with the alleged embezzlement. It noted that public employment alone does not establish action under color of state law when officials act privately.

As to the medical allegations, the court said Adams might be able to assert an Eighth Amendment claim if he was a convicted prisoner or a Fourteenth Amendment claim if he was a pretrial detainee. But the complaint did not adequately describe his serious medical needs, the effects of the wrong medication, which sexually transmitted diseases required treatment, how the alleged medical-record falsification and failure to treat diabetes harmed him, or what each defendant knew about and did in response to a serious risk of harm.

Timeliness

The court explained that § 1983 claims in California generally use a two-year limitations period for personal-injury actions, while federal law determines when a claim accrues. It found that the latest alleged event was the July 25, 2018 threat by Deputy Inglestate and that Adams filed the action more than four years later. The court also stated that the complaint indicated Adams knew or had reason to know of the alleged injuries when the earlier events occurred. It therefore found that the action was subject to dismissal as untimely because the limitations defense was complete and obvious from the pleadings.

The court nevertheless gave Adams an opportunity to allege facts defeating the limitations defense. It warned that if he could not overcome the timeliness problem, all claims would have to be dismissed even if they were otherwise legally sufficient.

Disposition

The court ordered that the complaint was DISMISSED with leave to amend. Adams had 28 days from the filing of the order to file an amended complaint using the same case caption and number and labeling the first page “AMENDED COMPLAINT.” The amended complaint would replace the original complaint; claims or defendants omitted from it would no longer be part of the action. The court further ordered that failure to respond as required and within the deadline would result in dismissal with prejudice of the action for failure to state a claim, without further notice. The order itself did not dismiss the action with prejudice.