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Matthews v. United States
3:16-cv-00077
D. Nev.
Jun 24, 2016
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Background

  • Plaintiff Felton L. Matthews, Jr., a Nevada state prisoner at Ely State Prison, filed a civil complaint in state court against multiple local, state, and federal actors; the United States and federal agencies removed the case to federal court.
  • Matthews moved for preliminary/permanent injunctive relief soon after removal and later filed a motion for partial summary judgment; the federal defendants moved to dismiss.
  • The magistrate judge issued a Report and Recommendation dismissing the Federal Government defendants and, in a separate screening order under 28 U.S.C. § 1915A, dismissed the remaining claims without prejudice with leave to amend.
  • Matthews’ injunctive motion primarily repeated the complaint’s allegations and did not develop legal arguments showing probable success on the merits.
  • The magistrate judge found Matthews’ summary-judgment motion premature (filed before defendants were served/appeared) and moot because the judicial and quasi-judicial defendants were immune and there were no viable claims pending against them.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether preliminary or permanent injunctive relief should issue Matthews seeks injunctions repeating the complaint’s allegations and requests various relief Federal Government opposed; dismissal motions argued claims not cognizable Denied as moot and for failure to show likelihood of success; motion dismissed without prejudice
Whether plaintiff showed likelihood of success on the merits for injunctive relief Matthews asserts entitlement but offers only conclusory allegations Defendants relied on briefing and motions to dismiss; court found defect in pleadings Held that Matthews failed to demonstrate probable success; injunctive motion lacks necessary showing
Whether injunctive relief is justiciable after court’s dismissal/recommendation Matthews requested relief tied to dismissed claims Defendants argued motions were mooted by dismissals Court held motions were moot because dismissal of claims eliminated case-or-controversy
Whether partial summary judgment against judges/clerks is proper Matthews seeks judgment and injunctive relief against Judge Gary Fairman and court clerks Defendants and court note judicial/quasi-judicial immunity and lack of service/appearance; premature filing Denied without prejudice as premature and moot given immunity and dismissal of claims

Key Cases Cited

  • Munaf v. Geren, 553 U.S. 674 (2008) (preliminary injunctive relief is extraordinary and not awarded as of right)
  • Winter v. Nat. Res. Def. Council, 555 U.S. 7 (2008) (four-factor preliminary injunction standard)
  • Arc of Cal. v. Douglas, 757 F.3d 975 (9th Cir. 2014) (Ninth Circuit’s sliding-scale approach for injunctions)
  • All. for the Wild Rockies v. Cottrell, 632 F.3d 1127 (9th Cir. 2011) (serious questions/balance of hardships standard)
  • De Beers Consol. Mines v. United States, 325 U.S. 212 (1945) (preliminary relief must be of same character as final relief)
  • Pac. Radiation Oncology, LLC v. Queen's Medical Ctr., 810 F.3d 631 (9th Cir. 2015) (injunctive relief must relate to underlying complaint’s conduct)
  • Gilmore v. California, 220 F.3d 987 (9th Cir. 2000) (PLRA limits equitable relief in prison-condition cases)
  • Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standards)
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Case Details

Case Name: Matthews v. United States
Court Name: District Court, D. Nevada
Date Published: Jun 24, 2016
Docket Number: 3:16-cv-00077
Court Abbreviation: D. Nev.