Hedrington v. United States
1:24-cv-00497
E.D. Cal.Sep 27, 2024Background
- Plaintiff Orlonzo Hedrington, acting pro se, alleged constitutional violations and intentional infliction of emotional distress against the United States based on an alleged assault at David Grant Medical Center on Travis Air Force Base.
- Hedrington alleged he was drugged, kidnapped, and assaulted by hospital staff, who then falsified records and conspired to conceal the alleged events.
- The present case is the latest in a series of lawsuits (six prior cases) by Hedrington or his bankruptcy trustee, all arising from the same alleged incident.
- The United States moved to dismiss the complaint under Rules 12(b)(1) (lack of subject matter jurisdiction) and 12(b)(6) (failure to state a claim).
- The government argued sovereign immunity bars § 1983 constitutional claims against the federal government, and res judicata precludes relitigating the intentional infliction of emotional distress claim.
- The court granted the government's motion to dismiss all claims, and ordered the case closed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| § 1983 claims against the United States | U.S. liable under § 1983 for constitutional violations | Sovereign immunity bars § 1983 claims vs. federal gov | Dismissed: Sovereign immunity applies |
| Intentional infliction of emotional distress | Claim not previously decided; not precluded by prior case | Claim is barred by res judicata due to prior cases | Dismissed: Res judicata precludes claim |
| Fraud on the court (exception to res judicata) | Prior rulings resulted from judicial/systemic fraud | No fraud demonstrated in prior proceedings | No exception: Argument meritless |
Key Cases Cited
- FDIC v. Meyer, 510 U.S. 471 (Sovereign immunity shields federal govt unless waived)
- Safe Air for Everyone v. Meyer, 373 F.3d 1035 (Facial attack on subject matter jurisdiction standard)
- Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (Dismissal for lack of legal theory or facts under 12(b)(6))
- Owens v. Kaiser Found. Health Plan, Inc., 244 F.3d 708 (Res judicata bars re-litigation of claims)
