Randle v. Contra Costa County Conflicts Panel

Background

Ramello D. Randle, an inmate in the Contra Costa County Jail proceeding without an attorney, filed a civil-rights complaint under 42 U.S.C. § 1983. He sued three attorneys—Anthony Guy Ashe, Lawrence Steven Strauss, and Matthew Fregi—who were successively appointed to represent him in criminal proceedings in Contra Costa County Superior Court. He also sued the Contra Costa County Conflicts Panel and the Panel’s supervisor, whom the court identified only as “the Supervisor” because the complaint provided only her first name.

Randle alleged that the attorneys provided inadequate representation. He claimed they refused to prepare a defense, hire needed experts, call favorable witnesses, produce evidence, and file critical motions. He also alleged that he had conflicts with the attorneys and that the Supervisor and the trial judge disregarded his complaints. He claimed racial discrimination, bias, defamation, mental abuse, and deprivation of his right to a fair trial. He sought monetary damages.

Screening standard

Because Randle was a prisoner seeking relief from governmental entities or personnel, the court screened the complaint under 28 U.S.C. § 1915A. The court was required to identify claims that could proceed or dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also explained that an unrepresented party’s filing must be read liberally, but must still allege enough facts to state a plausible claim.

To state a claim under Section 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—that is, using authority connected to state government.

Claims against the appointed attorneys

The court held that Randle’s Section 1983 claims against Ashe, Strauss, and Fregi were not capable of judicial determination because appointed criminal defense attorneys do not act under color of state law when performing traditional defense functions. The court treated preparing a defense, hiring experts, calling witnesses, producing evidence, and filing motions as traditional functions of criminal defense counsel. As a result, the complaint did not satisfy the state-action element required for a Section 1983 claim against these defendants.

Claims against the Supervisor and Conflicts Panel

Randle alleged that the Supervisor assigned the three attorneys even though they had not previously won a case involving a “lying in wait” murder special circumstance. The court said it was unclear whether the Supervisor was a state official, but ruled that, even if she was, the allegations described only the assignment of attorneys, not representation of Randle. The court found no cited or known authority establishing that an official violates a criminal defendant’s constitutional rights by assigning an attorney who later provides ineffective assistance. It also found no authority establishing a constitutional guarantee to an attorney who had previously won a case involving the same charges.

Randle did not allege whether the Conflicts Panel was an entity that could be sued separately from the Supervisor. The court stated that, even if it could be sued independently, the same reasoning applied: assigning the attorneys did not state a claim capable of judicial review and determination under Section 1983.

Disposition

The court concluded that amendment would be futile because Randle intended to sue the attorneys for traditional defense activities and the Supervisor and Conflicts Panel for assigning those attorneys. The court dismissed the case for failure to state a claim capable of judicial review and determination, denied leave to amend, and dismissed the case with prejudice. The Clerk was directed to enter judgment and close the file.