Aguilar v. Tafelmeyer

District Court, D. Nevada·Decided December 12, 2024·No. 3:23-cv-00547·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Case No.: 3:23-cv-00547-ART-CSD DAVID AGUILAR, 4 Order Plaintiff 5 Re: ECF No. 47 v. 6 TAFELMEYER, et al., 7 Defendants 8

9 Before the court is Plaintiff’s second motion for leave to amend his complaint and 10 proposed first amended complaint (FAC). (ECF Nos. 47, 47-1) Defendants filed a response. 11 (ECF Nos. 54, 54-1.) Plaintiff filed a reply. (ECF No. 55.) 12 For the reasons set forth below, the motion is granted. 13 I. BACKGROUND 14 Plaintiff is an inmate in custody of the Nevada Department of Corrections (NDOC). 15 When he filed this action, he was proceeding pro se, but he was subsequently appointed pro bono 16 counsel. 17 The court screened Plaintiff’s original complaint and allowed him to proceed with an 18 Eighth Amendment excessive force claim against defendants Johnson, Tafelmeyer, Mahon, and 19 Sheeks, and an Eighth Amendment deliberate indifference to serious medical needs claim against 20 Tafelmeyer. 21 Plaintiff, through his counsel, then filed a motion for leave to amend and proposed 22 amended complaint to add a claim for relief under the Americans with Disabilities Act (ADA) 23 against NDOC. (ECF Nos. 38, 38-1.) 1 The undersigned issued a report and recommendation that the motion to be denied 2 because Plaintiff did not state a plausible claim for relief under the ADA, and the Eighth 3 Amendment deliberate indifference to serious medical needs claim was asserted against all four 4 individual defendants, but there were only allegations regarding a denial of medical care as to

5 Tafelmeyer. (ECF No. 45.) 6 Plaintiff then withdrew the motion for leave to amend (ECF No. 46), rendering the report 7 and recommendation moot. Plaintiff has filed a new motion for leave to amend and proposed 8 FAC. (ECF Nos. 47, 47-1.) The proposed FAC once again seeks to include an ADA claim 9 against NDOC, as well as an Eighth Amendment deliberate indifference to serious medical needs 10 claim against only Tafelmeyer, and an Eighth Amendment excessive force claim against 11 Johnson, Tafelmeyer, Mahon, and Sheeks. 12 II. LEGAL STANDARD 13 “A party may amend its pleading once as a matter of course within: (A) 21 days after 14 serving it, or (B) if the pleading is one to which a responsive pleading is required, 21 days after

15 service of a responsive pleading or 21 days after service of a motion under Rule 12(b), (e), or (f), 16 whichever is earlier.” Fed. R. Civ. P. 15(a)(1)(A), (B). Otherwise, a party must seek the opposing 17 party’s written consent or leave of court to amend a pleading. Fed. R. Civ. P. 15(a)(2). Here, 18 Plaintiff was required to seek leave to amend. 19 “The court should freely give leave when justice so requires.” Fed. R. Civ. P. 15(a)(2). 20 Leave to amend need not be given where amendment: “(1) prejudices the opposing party; (2) is 21 sought in bad faith; (3) produces an undue delay in litigation; or (4) is futile.” Amerisource 22 Bergen Corp. v. Dialysist West, Inc., 465 F.3d 946, 951 (9th Cir. 2006) (citation omitted). 23 1 In addition, under 28 U.S.C. § 1915A, “[t]he court shall review, before docketing, if 2 feasible or, in any event, as soon as practicable after docketing, a complaint in a civil action in 3 which a prisoner seeks redress from a governmental entity or officer or employee of a 4 governmental entity.” 28 U.S.C. § 1915A(a). In conducting this review, the court “shall identify

5 cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint-- 6 (1) is frivolous, malicious, or fails to state a claim upon which relief may be granted; or (2) seeks 7 monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b)(1)-(2). 8 Dismissal of a complaint for failure to state a claim upon which relief may be granted is 9 provided for in Federal Rule of Civil Procedure 12(b)(6), and 28 U.S.C. § 1915A(b)(1) tracks 10 that language. As such, when reviewing the adequacy of a complaint under these statutes, the 11 court applies the same standard as is applied under Rule 12(b)(6). See e.g. Watison v. Carter, 668 12 F.3d 1108, 1112 (9th Cir. 2012). Review under Rule 12(b)(6) is essentially a ruling on a question 13 of law. See Chappel v. Lab. Corp. of America, 232 F.3d 719, 723 (9th Cir. 2000) (citation 14 omitted).

15 The court must accept as true the allegations, construe the pleadings in the light most 16 favorable to the plaintiff, and resolve all doubts in the plaintiff’s favor. Jenkins v. McKeithen, 17 395 U.S. 411, 421 (1969) (citations omitted). Allegations in pro se complaints are “held to less 18 stringent standards than formal pleadings drafted by lawyers[.]” Hughes v. Rowe, 449 U.S. 5, 9 19 (1980) (internal quotation marks and citation omitted). 20 A complaint must contain more than a “formulaic recitation of the elements of a cause of 21 action,” it must contain factual allegations sufficient to “raise a right to relief above the 22 speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). “The pleading 23 must contain something more … than … a statement of facts that merely creates a suspicion [of] 1 a legally cognizable right of action.” Id. (citation and quotation marks omitted). At a minimum, a 2 plaintiff should include “enough facts to state a claim to relief that is plausible on its face.” Id. at 3 570; see also Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 4 III. DISCUSSION

5 Defendants argue that amendment would be futile because Plaintiff failed to exhaust 6 administrative remedies; however, the court must take Plaintiff’s allegations as true for pleading 7 purposes, and exhaustion is an affirmative defense that must be raised in a motion for summary 8 judgment unless the failure to exhaust is clear from the face of the complaint. Albino v. Baca, 9 747 F.3d 1162, 1166 (9th Cir. 2014). Here, exhaustion is not clear from the face of the 10 complaint, and is not properly raised in response to Plaintiff’s motion for leave to amend. 11 Therefore, this is not a basis to deny the motion for leave to amend. 12 Defendants also argue that amendment is futile because Plaintiff fails to articulate an 13 ADA claim. 14 The court finds that, unlike the previous proposed amended complaint, Plaintiff states a

15 colorable claim for relief under the ADA against NDOC. 16 Title II of the ADA, which prohibits discrimination on the basis of disability, applies in 17 the prison context. See United States v.

Free access — add to your briefcase to read the full text and ask questions with AI

Aguilar v. Tafelmeyer, (D. Nev. 2024).

Aguilar v. Tafelmeyer (Aguilar v. Tafelmeyer) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Jenkins v. McKeithen
395 U.S. 411 (Supreme Court, 1969)
Hughes v. Rowe
449 U.S. 5 (Supreme Court, 1980)
United States v. Georgia
546 U.S. 151 (Supreme Court, 2006)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
O'GUINN v. Lovelock Correctional Center
502 F.3d 1056 (Ninth Circuit, 2007)
Juan Albino v. Lee Baca
747 F.3d 1162 (Ninth Circuit, 2014)
Lovell v. Chandler
303 F.3d 1039 (Ninth Circuit, 2002)