Taylor v. Price

Background

Eugene Elridge Taylor, a civil detainee at Coalinga State Hospital, filed a self-represented action under 42 U.S.C. § 1983 against Warden Brandon Price. Taylor stated that he was confined under California’s Sexually Violent Predator Act. He sought to prevent what he described as an arbitrary deprivation, asked that the state’s sexually violent predator petition be dropped for lack of substantial evidence, and asked why he had not been released from “prison custody” since July 2, 1986.

Court’s analysis

The court screened the complaint under 28 U.S.C. § 1915A, which requires early review of a civil action seeking relief from a governmental officer. The court explained that a § 1983 claim requires an alleged violation of a federal constitutional or statutory right by someone acting under state law.

The court concluded that Taylor was challenging his continuing civil commitment itself. It held that § 1983 was not the proper vehicle for that challenge. Instead, the constitutionality of state civil-commitment proceedings could be challenged through a federal habeas petition—a petition asking a court to review allegedly unlawful detention—after state remedies had been exhausted. The court stated that a civil-rights complaint seeking habeas relief should be dismissed without prejudice to refiling as a petition under 28 U.S.C. § 2254.

The court further stated that the preferred federal forum was the district where Taylor was confined. Because Taylor was committed at Coalinga State Hospital in Fresno County, the court directed that any such habeas action be filed in the Eastern District of California.

Disposition

The court dismissed the action without prejudice. It denied Taylor’s motion for a “speedy trial,” listed at Docket No. 3, as moot, and terminated that docket entry. The court stated that Taylor could file a federal petition challenging his continuing civil commitment in the Eastern District of California, provided he had first exhausted his state-court remedies.