Card v. Chin

Background

Christopher Lee Card, who was incarcerated at Santa Rita Jail and represented himself, filed a civil-rights action under 42 U.S.C. § 1983. He sought monetary damages, punitive damages, injunctive relief, and an emergency injunction. The complaint concerned Card’s ongoing criminal case in Alameda County Superior Court, including proceedings about his mental competency and possible placement in a mental institution.

Card named Judge Jason Chin; Alameda County Deputy District Attorney Kevin Ikuma; Alameda County Public Defenders Sue Ra and Joshi Valentine; and psychologists Dr. Amy Watt and Dr. Marlin Griffith. He alleged conspiracy, judicial misconduct, collusion, perjury, falsification of documents, abuse of process, and attorney misconduct. The opinion states that the handwritten complaint was sometimes difficult to decipher.

Screening and injunctive relief

Because Card was a prisoner seeking relief from government officials, the court screened the complaint under 28 U.S.C. § 1915A. The court explained that screening requires dismissal of claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant.

The court applied the Younger abstention doctrine, which generally requires federal courts not to interfere with ongoing state criminal proceedings. It found that all three required conditions were met: Card’s state criminal proceedings were ongoing; the proceedings implicated important state interests; and Card could present his federal claims in the state trial and appellate courts. The court also found no plausible allegation of the extraordinary circumstances—such as immediate irreparable harm, bad faith, harassment, or a biased state tribunal—that could justify federal intervention.

The court concluded that Card’s requested injunctions would interfere with the state proceedings, including his requests that a federal court direct Judge Chin to stop placement orders or prevent forced medication. It therefore dismissed Card’s claims for injunctive relief because abstention was warranted.

Claims for monetary damages

The court dismissed Card’s claims against Judge Chin because the challenged decisions were made in the judge’s judicial capacity, which gave him absolute judicial immunity.

The court dismissed the claims against Deputy District Attorney Ikuma because a prosecutor acting as an advocate in initiating and pursuing a criminal case has absolute prosecutorial immunity.

The court held that Card could not state a § 1983 claim against Public Defenders Ra and Valentine based on allegedly deficient representation. Public defenders do not act under color of state law when performing traditional lawyer functions, including representation related to a client’s mental competency.

The court also held that Drs. Watt and Griffith had absolute witness immunity for alleged perjury in statements made to the state superior court. The court dismissed all monetary-damages claims against the judge, deputy district attorney, public defenders, and court-appointed psychologists without leave to amend.

Disposition

The action was dismissed because Younger abstention was warranted as to the claims for injunctive relief. The monetary-damages claims against all named defendants were dismissed without leave to amend. The court denied Card’s request for an emergency injunction as moot, certified that an appeal proceeding without payment of filing fees would not be taken in good faith, and directed the clerk to close the file.