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