Michael Manjeet Singh v. Warden Pheiffer, et al.

Summary

The United States District Court for the Eastern District of California converts Defendants’ partial motion to dismiss Plaintiff’s state-law claims under the California Government Claims Act into a motion for summary judgment. The court gives the parties 30 days to submit additional argument or evidence, provides notice of the requirements for opposing summary judgment, and permits a request for discovery-related abeyance.

Holdings

1. When both parties rely on documents outside the complaint to resolve a factual and legal issue, and the issue cannot be determined from the face of the complaint, the court may properly convert the Rule 12(b)(6) motion into a motion for summary judgment under Rule 12(d), rather than exclude the extrinsic materials.
2. Before summary judgment may be entered against a party, the party must receive notice that the motion is pending and an adequate opportunity to respond, including sufficient time for necessary discovery; these notice requirements must be strictly followed when the nonmoving party is appearing pro se.

Questions Presented

1. Whether the court should consider documents outside the pleadings in resolving Defendants' Rule 12(b)(6) motion.
2. Whether the partial motion to dismiss should be converted into a motion for summary judgment under Federal Rule of Civil Procedure 12(d).
3. What notice and opportunity to respond must be provided to a pro se prisoner after conversion to summary judgment.

Disposition

other