(PS) Adams v. Bonta
2:24-cv-03300
E.D. Cal.May 23, 2025Background
- Plaintiff Brandon G. Adams filed a complaint against Rob Bonta and others in the Eastern District of California.
- On January 29, 2025, the court dismissed the original complaint for failure to state a claim, granting Adams thirty days to amend or voluntarily dismiss.
- Instead of amending, Adams filed objections and other unrelated documents, which were not considered proper amendments.
- On March 26, 2025, the court issued an order to show cause, warning that noncompliance would result in dismissal of the action.
- Adams again failed to amend or show cause, instead repeating previous objections and filings that lacked factual allegations.
- The court now recommends dismissal without prejudice for failure to prosecute, obey court orders, and state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to state a claim | Cites statutes and constitution without facts | Not clearly stated | Court: Adequate grounds for dismissal for failure to state a claim |
| Failure to prosecute/amend complaint | Filed objections and forms instead of amending | Not clearly stated | Court: Noncompliance justifies dismissal |
| Obedience to court orders | Plaintiff did not comply with orders to amend | Not clearly stated | Court: Repeated noncompliance supports dismissal |
| Appropriateness of sanctions (dismissal) | Does not address sanctions appropriateness | Not clearly stated | Court: Dismissal warranted & less drastic measures considered |
Key Cases Cited
- Bautista v. Los Angeles Cnty., 216 F.3d 837 (9th Cir. 2000) (court has inherent power to impose sanctions, including dismissal)
- Ghazali v. Moran, 46 F.3d 52 (9th Cir. 1995) (dismissal for noncompliance with local rules permissible)
- Ferdik v. Bonzelet, 963 F.2d 1258 (9th Cir. 1992) (failure to comply with order to amend can justify dismissal)
- Carey v. King, 856 F.2d 1439 (9th Cir. 1988) (dismissal proper for failure to comply with local rule to keep court apprised of address)
- Malone v. U.S. Postal Serv., 833 F.2d 128 (9th Cir. 1987) (noncompliance with court order can warrant dismissal)
- Henderson v. Duncan, 779 F.2d 1421 (9th Cir. 1986) (dismissal appropriate for lack of prosecution and local rule violations)