Calzada v. Commonwealth of Massachusetts

Background

Christopher Lee Calzada, who was incarcerated at the Old Colony Correctional Center in Massachusetts, filed the action without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims for violations of federal rights by state actors. The court had allowed him to proceed without paying the filing fee at the start of the case.

Calzada alleged that events occurred from “1986 through 2021, 2026.” His allegations included claims that factories, buildings, hospitals, property, body armor, and federal property had been stolen and used for others’ benefit; that people had harmed or interfered with his body; and that he and his family had been threatened and stalked. He also alleged illegal imprisonment, inhumane treatment, efforts to use his head and body for investigations, and threats against people who spoke about these matters. He sought damages and the return of body armor and other allegedly stolen property.

Screening standard

The Prison Litigation Reform Act requires courts to screen complaints filed by incarcerated people against governmental entities or government officers. The court must dismiss a complaint, or part of it, if it is frivolous or malicious, fails to state a legally sufficient claim, seeks money from an immune defendant, or falls outside the court’s subject-matter jurisdiction. Although courts read complaints filed without lawyers liberally, those complaints still must provide enough factual information to make a claim plausible.

Court’s reasoning

To state a claim under Section 1983, a plaintiff must allege both a violation of a right secured by the Constitution or federal law and conduct by a person acting under state authority.

The court held that the Commonwealth of Massachusetts was protected by Eleventh Amendment immunity, a legal protection that generally prevents states from being sued in federal court. The court explained that this immunity covers claims for money damages, injunctive relief, and retrospective declaratory relief. It further stated that Congress had not removed Massachusetts’s immunity for Section 1983 claims and that Massachusetts had not waived it.

The court therefore dismissed Calzada’s claims against Massachusetts under Eleventh Amendment immunity and because the claims were frivolous. The court stated that an amendment could not cure these defects, so it declined to give Calzada permission to amend his complaint.

Disposition

The court dismissed Calzada’s complaint under 28 U.S.C. § 1915(e)(2)(B)(i)–(iii). Judge Laura Taylor Swain also certified that an appeal would not be taken in good faith and denied Calzada permission to proceed without paying fees for an appeal. The opinion does not describe any separate ruling on the specific constitutional violations alleged in the complaint.