Ari v. Montes, 3:20-cv-06000

Plaintiff Roxanne Ari is a California state prisoner who filed suit seeking relief related to both her 1990 Contra Costa County conviction and the conditions of her confinement.
The district court previously dismissed the original complaint with leave to amend, instructing Ari to proceed with either a habeas petition (challenging conviction) or a § 1983 complaint (challenging conditions), not both.
In the amended filings Ari again raised forced-medication claims arising at a facility in the Central District of California while also seeking relief overturning or shortening her 1990 conviction (in this Northern District).
The court explained that challenges to the validity or duration of confinement are generally habeas claims (exclusive remedy for release), whereas conditions-of-confinement claims belong in a § 1983 action in the proper venue.
Ari did not show why a habeas petition challenging her 1990 conviction would not be untimely or successive under AEDPA’s one-year limit, and she failed to correct the prior deficiencies after being given leave to amend.
The court granted Ari’s in forma pauperis motions but dismissed the action without leave to amend, directed the clerk to close the case, and instructed Ari to file any conditions-of-confinement complaint in the Central District of California.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper procedural vehicle: conviction challenge vs. conditions claim	Ari sought relief overturning her conviction and relief for forced medication (combined)	Montes (and court) argued conviction challenges belong in habeas; conditions belong in § 1983 in correct venue	Court held Ari must proceed either by habeas (for conviction) or § 1983 (for conditions); directed conditions claims to Central District
Venue for conditions claims	Forced-medication claims arise from confinement at facility in Central District	Venue is improper in Northern District for conditions occurring in Central District	Court held conditions claims belong in Central District and sent blank civil-rights complaint form
AEDPA timeliness/successive-petition issue for 1990 conviction	Ari sought to overturn or obtain early release but did not show why habeas would not be untimely or successive	Court required explanation why a habeas petition is not barred by AEDPA’s one-year rule or is not successive	Court dismissed conviction challenge for failure to address AEDPA timeliness/successiveness; dismissed case without leave to amend
Leave to amend	Ari previously given leave to amend but failed to cure defects	Court argued plaintiff already had opportunity and did not fix deficiencies	Court denied further leave and dismissed the action without leave to amend

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions must be supported by factual allegations)
Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (9th Cir. 1990) (pro se pleadings are liberally construed)
West v. Atkins, 487 U.S. 42 (1988) (§ 1983 requires state action and a constitutional violation)
Hill v. McDonough, 547 U.S. 573 (2006) (distinguishes habeas relief from § 1983 conditions claims)
Muhammad v. Close, 540 U.S. 749 (2004) (habeas is the proper vehicle for certain challenges to confinement)
Skinner v. Switzer, 562 U.S. 521 (2011) (habeas is exclusive remedy for claims seeking immediate or speedier release)
Wilkinson v. Dotson, 544 U.S. 74 (2005) (habeas vs. § 1983 distinction for prisoner claims)
Preiser v. Rodriguez, 411 U.S. 475 (1973) (successive, overlapping habeas and § 1983 doctrines)
Nettles v. Grounds, 830 F.3d 922 (9th Cir. 2016) (en banc) (§ 1983 is exclusive for some prisoner claims not at habeas core)
Thornton v. Brown, 757 F.3d 834 (9th Cir. 2014) (success on certain claims would necessarily shorten confinement; thus habeas core)