(PC) Gonzalez-Garcia v. Baker
2:20-cv-00234
E.D. Cal.Apr 21, 2020Background
- Plaintiff Rodrigo Gonzalez-Garcia, a pro se detainee at Shasta County Jail, filed a 42 U.S.C. § 1983 suit claiming his Sixth Amendment speedy-trial rights are being violated.
- The district court screened the original complaint under 28 U.S.C. § 1915A and dismissed it with leave to amend; an amended complaint was subsequently filed.
- The amended pleading is vague and confusing but seeks release from custody and money damages.
- The magistrate judge applied screening standards: dismiss if claims are frivolous, fail to state a claim, or seek relief from immune defendants (28 U.S.C. § 1915A(b)).
- The court concluded release is not available in a § 1983 action (Preiser), and damages claims that imply the invalidity of confinement are barred under Heck.
- The magistrate recommended dismissing the amended complaint for failure to state a claim, finding further amendment futile, and recommended closing the case; objections were permitted within 14 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff may obtain release from custody via § 1983 | Gonzalez-Garcia seeks release for alleged speedy-trial violation | Defendants: relief by release is not cognizable in § 1983 (habeas proper) | Dismissed: release is not available in § 1983; habeas is the proper remedy (Preiser) |
| Whether plaintiff may recover damages for claims that imply invalidity of confinement | Seeks money damages for alleged Sixth Amendment violation | Defendants: damages barred if success would imply invalidity of conviction/detention | Dismissed or barred: damages not allowed where success would imply invalidity of confinement (Heck) |
| Whether the amended complaint states a viable § 1983 claim and whether amendment should be allowed | Argues speedy-trial violation supports § 1983 relief | Defendants: under screening standard, claim fails to state a claim; legal doctrines preclude relief | Held: Amended complaint fails to state a claim; further amendment would be futile; recommend dismissal and case closure |
Key Cases Cited
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (release from custody is not available under § 1983; habeas corpus is the proper remedy)
- Heck v. Humphrey, 512 U.S. 477 (1994) (a § 1983 claim for damages that would imply the invalidity of confinement is not cognizable until conviction or confinement has been invalidated)
- Martinez v. Ylst, 951 F.2d 1153 (9th Cir. 1991) (failure to file timely objections to magistrate findings waives right to appeal)