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James Hydrick v. Peter Wilson
711 F. App'x 813
| 9th Cir. | 2017
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Background

  • Plaintiffs are a class of sexually violent predators (SVPs) who sued challenging conditions at California state hospitals; the operative pleading is the Second Amended Complaint (SAC).
  • Plaintiffs were transferred from Atascadero State Hospital to Coalinga State Hospital after filing; they sought injunctive relief and some system‑wide relief.
  • The district court dismissed the complaint as moot, denied plaintiffs’ motions to amend the complaint, to transfer venue under 28 U.S.C. § 1404(a), and to extend time for service under Fed. R. Civ. P. 4(m).
  • Plaintiffs appealed, arguing their claims were not moot and that the district court abused its discretion in denying leave to amend and in denying transfer.
  • The Ninth Circuit reviewed mootness de novo and reviewed denial of motions to amend, to transfer, and for extension of service for abuse of discretion, and affirmed dismissal.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Mootness of facility‑specific injunctive claims Transfer from Atascadero to Coalinga does not moot claims because relief could still benefit plaintiffs Transfer to a different facility typically moots facility‑specific injunctive claims Claims were moot; transfer mooted challenges to Atascadero officials (Nelson/Dilley rule)
Viability of system‑wide claims / personal jurisdiction via service Plaintiffs contend they asserted system‑wide claims that survive transfer Even if system‑wide claims asserted, defendants who could provide system relief were not timely served, so no personal jurisdiction Court assumed arguendo system claims but concluded service failures under Rule 4(m) meant district court lacked jurisdiction over those defendants; denial of extension was not an abuse of discretion
Denial of leave to amend (to add new facility/defendants) Amendment would cure defects and permit system/facility claims to proceed Proposed Third Amended Complaint would be futile and prejudicial and was sought after undue delay Denial affirmed: amendment futile (same policymakers not timely served), would create venue problems and prejudice, and delay was unexplained
Denial of transfer under 28 U.S.C. § 1404(a) Transfer to appropriate venue would allow claims to proceed and avoid mootness Even if transferred, the SAC claims would remain moot; transfer unnecessary Denial not an abuse of discretion because transfer would not cure mootness

Key Cases Cited

  • Native Vill. of Noatak v. Blatchford, 38 F.3d 1505 (9th Cir. 1994) (standard for reviewing dismissal for mootness)
  • Bayer v. Neiman Marcus Grp., Inc., 861 F.3d 853 (9th Cir. 2017) (injunctive‑relief mootness standard)
  • Nelson v. Heiss, 271 F.3d 891 (9th Cir. 2001) (transfer moots facility‑specific prison claims)
  • Dilley v. Gunn, 64 F.3d 1365 (9th Cir. 1995) (same)
  • Walker v. Beard, 789 F.3d 1125 (9th Cir. 2015) (system‑wide claims require a defendant able to provide relief)
  • Efaw v. Williams, 473 F.3d 1038 (9th Cir. 2007) (Rule 4(m) good cause standard for extension of service)
  • Ventress v. Japan Airlines, 603 F.3d 676 (9th Cir. 2010) (standard of review for denial of leave to amend and other discretionary motions)
  • Royal Ins. Co. of Am. v. Sw. Marine, 194 F.3d 1009 (9th Cir. 1999) (factors for denying leave to amend: bad faith, undue delay, prejudice, futility)
  • Acri v. Int’l Ass’n of Machinists & Aerospace Workers, 781 F.2d 1393 (9th Cir. 1986) (leave to amend may be denied for undue delay/prejudice)
  • Jackson v. Bank of Haw., 902 F.2d 1385 (9th Cir. 1990) (same)
  • Cold Mountain v. Garber, 375 F.3d 884 (9th Cir. 2004) (issues not raised below are waived on appeal)
Read the full case

Case Details

Case Name: James Hydrick v. Peter Wilson
Court Name: Court of Appeals for the Ninth Circuit
Date Published: Sep 26, 2017
Citation: 711 F. App'x 813
Docket Number: 16-55830
Court Abbreviation: 9th Cir.