William Brogan v. San Mateo County

William Brogan appeals pro se the dismissal of his section 1983 complaint challenging the constitutionality of the workfare program in San Mateo County and alleging that participation in the program violated his civil rights. We affirm.

FACTS

On June 10, 1988, Brogan filed a complaint in the district court for the Northern District of California, challenging his mandatory participation in San Mateo County’s Vocational Rehabilitation Program, required as a condition for receiving public assistance. Brogan claimed that the workfare program violated the thirteenth amendment of the United States Constitution and 18 U.S.C. § 1581 , which prohibits holding a person in a condition of peonage, and alleged a violation of his constitutional rights pursuant to 42 U.S.C. §§ 1983 and 1988. Brogan, who suffered a disabling heart attack at 61 years of age, alleged that the attack was a result of the poor working conditions in the workfare program, and asked for $250,000 in damages. He had filed a claim for $200,000 with the County Board of Supervisors, which was denied. Although San Mateo County does provide workers’ compensation benefits to participants in the work program, Brogan did not…