Adams v. San Francisco FBI

Background

Henry Desean Adams, identified as a state inmate, filed a civil-rights action under 42 U.S.C. § 1983 without a lawyer. The original complaint named an FBI agent, a Contra Costa County deputy district attorney, deputies from the Contra Costa County Sheriff’s Department, and medical staff at the Martinez Detention Facility. The court previously dismissed that complaint with permission to amend, identifying issues involving damages based on an allegedly unconstitutional conviction under Heck v. Humphrey, alleged property seizures, medical care, and timeliness.

Adams filed an amended complaint naming only an unknown FBI special agent and Deputy District Attorney Kabu Adodojaji. He alleged that he was arrested on June 18, 2015, and placed in the Contra Costa County Martinez Detention Facility. He described alleged pressure to accept a plea deal, denial of treatment for chlamydia, gonorrhea, and diabetes, restrictive or prolonged housing moves, identity theft and fraudulent purchases by county employees, the FBI’s refusal to investigate reports of fraud, stolen funds from his inmate account, and problems involving hidden evidence in his criminal case. He sought damages, expungement of arrest records, and release-related relief.

Court’s analysis

Because Adams sought relief from governmental entities or officers, the court screened the amended complaint under 28 U.S.C. § 1915A. To state a claim under § 1983, a plaintiff must allege both a violation of a federal constitutional or statutory right and conduct by a person acting under color of state law.

The court concluded that the amended complaint did not correct the deficiencies identified earlier:

- Adams did not state whether the conviction or sentence he challenged had been invalidated. The court said his request to expunge his arrest records indicated that it had not been invalidated, creating the issue identified under Heck concerning damages claims that would undermine an existing conviction or sentence. - Adams did not allege enough facts showing that the defendants acted under color of state law when they allegedly committed identity theft. The court explained that a public employee’s private conduct is not automatically state action merely because of the person’s government employment. - Although Adams described medical needs, he did not allege each defendant’s subjective awareness of a serious risk of harm and failure to address it. The only defendants named in the amended complaint were the unknown FBI agent and the deputy district attorney, whom Adams did not allege were involved in his medical care. - Adams did not provide facts addressing the court’s concern that most of the claims might be barred by the statute of limitations.

Disposition

The court found no good cause to allow another amendment because Adams had already received an opportunity to amend and the amended complaint retained the same deficiencies. The action was dismissed for failure to state a claim for relief. The clerk was directed to terminate all pending motions and close the file. The opinion does not state that the dismissal was with or without prejudice.