The following excerpt is from Hansen v. Arkley, No. 2:20-cv-02436-KJM-CKD (PS) (E.D. Cal. 2020):
Similarly, because an action under section 1986 cannot survive without a valid claim for relief under section 1985, plaintiffs have also failed to state a claim under 42 U.S.C. section 1986. Trerice v. Pedersen, 769 F.2d 1398, 1403 (9th Cir. 1985) ("[The Ninth Circuit has] adopted the broadly accepted principle that a cause of action is not provided under 42 U.S.C. 1986 absent a valid claim for relief under section 1985.").
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