Reyna v. City of Santa Cruz

Background

Rhonda E. Reyna filed a self-represented civil-rights action under 42 U.S.C. § 1983. The complaint named 54 defendants, including the City and County of Santa Cruz, the County of San Mateo, sheriff’s offices, a county family court, law-enforcement officers, judges, school officials, attorneys, domestic-violence agencies, a court reporter, and other entities or individuals. It asserted six claims involving the First, Second, Fourth, Eighth, Fourteenth, and Sixth Amendments and sought compensatory and punitive damages and injunctive relief.

The complaint described events from 2014 through 2023 concerning Reyna’s family-law and child-custody case. It also described a June 28, 2021 arrest by Santa Cruz police officers and alleged force against Reyna and her daughter, identified as B.M. The court stated that it was not deciding whether the complaint’s allegations were true.

Rulings on the applications

The court granted Reyna’s application to proceed without prepaying filing fees. It denied her request to undo the order vacating a prior judge’s fee-status order and to reinstate that order, while leaving in place the prior finding that she met the income requirements for fee-free litigation. The court also denied her request to transfer the case to the San Jose Division. The court said it could consider accommodations for hearings and noted that papers could be filed electronically, by mail, or through a courthouse drop box.

Screening of the complaint

Because Reyna was allowed to proceed without prepaying fees, the court screened the complaint under 28 U.S.C. § 1915. That statute requires dismissal of claims that are frivolous, fail to state a legally sufficient claim, or seek money from a defendant immune from such relief. The court found that the complaint did not clearly identify which defendants were sued for which claims, and that some allegations did not provide enough dates to determine whether the claims were timely.

The court applied a two-year limitations period for § 1983 claims filed in California. It dismissed, without leave to amend, claims based on events before June 23, 2021, unless Reyna could show that those claims were timely. The court specifically identified allegations concerning earlier family-court proceedings, reports to sheriff’s and police departments, and interactions with a family-court mediator.

The court dismissed, without leave to amend, the claims against Judge Don Franchi and then-Commissioner Renee Reyna because the allegations concerned acts performed in their judicial capacities and judges have absolute immunity from damages claims for such acts. It also dismissed, without leave to amend, the claims against the San Mateo County Family Court because the court treated that entity as a state agency protected by sovereign immunity.

The court did not at that point dismiss the claims against San Mateo County District Attorney Inspector James Haggarty. Instead, it ordered Reyna to explain in an amended complaint why absolute prosecutorial immunity would not require his dismissal. The court stated that it might dismiss those claims without leave to amend if Reyna did not provide that explanation.

The court also instructed Reyna not to bring § 1983 claims against private individuals or organizations that were not acting under color of state law. If she continued to sue private parties, she had to identify the specific conduct allegedly amounting to state action.

Claims involving B.M. and family-court orders

The court found it unclear whether Reyna was asserting claims based on injuries she personally experienced while witnessing events involving B.M. or was trying to assert B.M.’s own claims. If Reyna sought to sue on B.M.’s behalf, B.M. would need to be added as a plaintiff. The court explained that a parent who is not a lawyer cannot represent a minor child in court. It also stated that the complaint did not provide enough information to determine what parental rights Reyna retained or whether the custody order prevented her from suing on B.M.’s behalf.

The court ordered any amended complaint either to remove claims brought on B.M.’s behalf or to add B.M. as a plaintiff and explain Reyna’s retained parental rights, any restriction in the custody order, and the steps being taken to obtain a lawyer.

The court dismissed, without leave to amend, claims asking the federal court to overturn San Mateo County Family Court rulings. It held that federal district courts lack authority to function as appeals courts reviewing state-court judgments under the Rooker-Feldman doctrine.

Possible effect of criminal proceedings

The court could not determine whether the rule from Heck v. Humphrey barred any claims because the complaint did not explain the status of the criminal charges related to Reyna’s arrest. That rule can prevent a civil-rights claim from proceeding when success would necessarily imply that an existing conviction or sentence is invalid, unless the conviction or sentence has already been overturned. The court also noted that pending criminal charges might require a stay of some or all of the civil case.

The court ordered Reyna to describe the charges, convictions, and any favorable termination of criminal proceedings connected to her claims. For any plea agreement, she was told to identify the offense to which she pleaded guilty or no contest, the dismissed charges, and the sentence. If she pursued an excessive-force claim based on the arrest, the court instructed her to explain why any resisting-arrest conviction would not bar that claim and encouraged her to provide more detail about the force allegedly used against her.

Disposition

The court dismissed the complaint with leave to amend and gave Reyna until October 17, 2023, to file an amended complaint addressing the identified problems. The court stated that the case might be dismissed for failure to prosecute if she did not meet the deadline. It granted fee-free status and denied both ex parte applications.