Randle v. Fregi

Background

Ramello Randle, an inmate in the Contra Costa County Jail proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. He sued Matthew Fregi, the court-appointed lawyer who represented him at his retrial, and Contra Costa County Superior Court Judge John W. Kennedy, who presided over his criminal trial. Randle had been convicted of first-degree murder on March 22, 2024.

Randle alleged that Fregi provided ineffective representation, failed to prepare a defense, failed to present favorable evidence and witnesses, and refused to file a motion for a mistrial. He alleged that Judge Kennedy violated his rights through various rulings during the criminal proceedings, including denying requests to replace Fregi and ordering Randle to wear restraints in view of the jury. Randle sought damages and a new trial in a different venue.

Screening Standard

Because Randle was a prisoner seeking relief from government-related defendants, the court screened the complaint under 28 U.S.C. § 1915A. The court was required to dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money damages from an immune defendant. To state a claim under § 1983, a plaintiff must allege both a violation of federal rights and action taken under color of state law, meaning action by someone exercising authority derived from state law.

Claims Against Fregi

The court held that Fregi’s alleged conduct involved traditional functions of a criminal defense lawyer, such as preparing a defense, presenting evidence and witnesses, and filing motions. Under the cited precedent, an appointed criminal defense lawyer does not act under color of state law while performing those traditional functions. The court therefore concluded that Fregi could not be held liable under § 1983 for the alleged inadequate representation.

Claims Against Judge Kennedy

The court held that Judge Kennedy was immune from Randle’s suit for actions taken while adjudicating Randle’s state-court criminal proceedings. The court stated that the challenged actions—ruling on requests for a different lawyer and ordering courtroom restraints—were functions normally performed by judges. It also stated that suits against individual state judges in their judicial capacity were barred by the Eleventh Amendment and that judges have absolute immunity from damages claims for judicial acts.

Disposition

The court concluded that amendment would be futile because the alleged conduct by Fregi was not action under color of state law and the alleged conduct by Kennedy was protected by judicial immunity. It dismissed the case for failure to state a claim capable of judicial review and determination, without leave to amend and with prejudice. The court denied Randle’s motion for appointment of counsel, directed the clerk to enter judgment and close the file, and terminated docket number 3.