Delvon C. Jackson v. Sarah Jones
2:17-cv-07843
C.D. Cal.Dec 4, 2017Background
- Pro se plaintiff Delvon C. Jackson sued Los Angeles County probation officer Sarah Jones (individual capacity) and Los Angeles County under 42 U.S.C. § 1983 for events during supervised probation after his April 16, 2015 release.
- Complaint alleges four claims: (1) violation of Fifth Amendment privilege against self-incrimination (incarceration after invoking Fifth); (2) substantive due process for denial of Fifth Amendment invocation; (3) procedural due process for incarceration without proper procedures; (4) Eighth Amendment cruel and unusual punishment based on treatment while jailed; requests compensatory and punitive damages.
- Plaintiff proceeded IFP and the Court screened the Complaint under 28 U.S.C. § 1915(e)(2) and Rule 12(b)(6) standards, applying liberal construction for pro se pleadings but requiring Rule 8 compliance and plausibility under Twombly/Iqbal.
- The Court found pervasive Rule 8 deficiencies: Complaint is long, internally inconsistent (different paragraph incorporations), and fails to give defendants fair notice of discrete claims and facts supporting each claim.
- For the County, Complaint contains no allegation of a policy or custom causing the violation (Monell), and an isolated incident cannot establish municipal liability.
- For Jones, the pleading fails to allege specific actions by her that caused the claimed deprivations; some claims potentially implicate absolute immunity for quasi-judicial probation functions, though arbitrary enforcement theory might survive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Municipal liability under § 1983 (Monell) | County liable for harms caused during Jones’s supervision of probation | County not liable absent an unconstitutional policy/custom showing; isolated incident insufficient | Dismissed as pleaded; no factual allegations of County policy/custom; leave to amend |
| Rule 8 & failure to state a claim | Complaint gives factual background supporting claims | Complaint is disorganized, incorporates inconsistent paragraphs, and fails to give fair notice to each defendant | Dismissed for Rule 8 and failure to state a claim; leave to amend with concise claims |
| Fifth Amendment / privilege against self-incrimination; immunity | Jones coerced self-incrimination and caused incarceration after invocation | Jones (as probation officer) may have absolute immunity for imposing/enforcing probation conditions | Court warned that Jones may be entitled to absolute immunity for quasi-judicial probation functions; claim insufficiently pleaded but arbitrary enforcement theory might proceed if properly alleged |
| Procedural due process & Eighth Amendment conditions of confinement | Jackson lacked probable-cause hearing, could not face accusers, and endured unconstitutional jail conditions | Jones did not oversee jail custody/deprivation; specific custodial actors not named; claims not tied to named defendants | Dismissed as pleaded for lack of factual allegations tying named defendants to hearings or jail conditions; leave to amend to name responsible actors and plead facts |
Key Cases Cited
- Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (local government liable only for its own policy or custom)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading must include factual content to state a plausible claim)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plaintiff must plead factual allegations raising claim above speculation)
- Swift v. California, 384 F.3d 1184 (probation/parole officials may have absolute immunity for quasi-judicial functions)
- Thornton v. Brown, 757 F.3d 834 (officers entitled to absolute immunity when imposing probation conditions pursuant to discretionary authority)
- McHenry v. Renne, 84 F.3d 1172 (Rule 8 requires concise, direct statement giving fair notice of claims)