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