Owens v. Lee

Background

Kenneth Oliver Owens, identified in the complaint as a pretrial detainee at the San Mateo County Jail, filed a complaint seeking damages under 42 U.S.C. § 1983. That statute allows a person to seek relief for violations of federal rights committed by someone acting under state law. Owens proceeded without a lawyer and also asked to proceed without prepaying the filing fee.

Owens sued several San Mateo County Superior Court judges and Deputy District Attorney Tabi Yasmin. He alleged that the judges improperly sided with Yasmin during his ongoing state criminal prosecution by allowing allegations involving prior “strike” convictions, refusing to accept an affidavit from the alleged victim, and allowing a juvenile who was not present at the scene to testify.

Court’s analysis

The court screened the complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner complaints against government entities or officials and dismiss claims that are frivolous, fail to state a claim, or seek money from defendants protected from such relief.

The court held that the named superior-court judges were immune from claims for money damages. Judicial immunity generally protects judges from damages lawsuits for judicial actions. The court found that Owens’s allegations did not involve nonjudicial actions or actions taken in a complete absence of jurisdiction.

The court also held that Deputy District Attorney Yasmin was immune from damages claims for conduct involved in pursuing a criminal prosecution while acting as the state’s advocate and in connection with the judicial phase of the criminal process.

Ruling

The court dismissed the action and denied Owens’s request to proceed without prepaying the filing fee because the damages action against the judges and prosecutor was frivolous or without merit. The opinion does not decide whether the alleged actions in Owens’s state criminal case were lawful; it resolves the federal damages action based on immunity.