Anderson v. Ely State Prison

CourtDistrict Court, D. Nevada
DecidedMay 14, 2025
Docket3:24-cv-00457
StatusUnknown

This text of Anderson v. Ely State Prison (Anderson v. Ely State Prison) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Ely State Prison, (D. Nev. 2025).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 JAYON ANDERSON, Case No. 3:24-cv-00457-ART-CLB 5 Plaintiff, ORDER 6 v.

7 ELY STATE PRISON, et al.,

8 Defendants.

9 10 I. DISCUSSION 11 This action began with a pro se civil rights complaint filed pursuant to 42 12 U.S.C. § 1983 by a state prisoner. Plaintiff has submitted an application to 13 proceed in forma pauperis. (ECF No. 24). Based on the financial information 14 provided, the Court finds that Plaintiff is unable to prepay the full filing fee in 15 this matter. 16 The Court entered a screening order on January 8, 2025. (ECF No. 29). The 17 screening order imposed a 90-day stay, and the Court entered a subsequent order 18 in which the parties were assigned to mediation by a court-appointed mediator. 19 (ECF Nos. 29, 40). The Office of the Attorney General has filed a status report 20 indicating that settlement has not been reached and informing the Court of its 21 intent to proceed with this action. (ECF No. 43). 22 During the stay, Plaintiff filed numerous motions. (ECF Nos. 31, 34, 35, 23 37, 39). The Court will consider each of Plaintiff’s claims in turn. 24 A. Motion for Appointment of Counsel 25 Plaintiff has filed a motion for appointment of counsel. (ECF No. 35). A 26 litigant does not have a constitutional right to appointed counsel in 42 U.S.C. § 27 1983 civil rights claims. Storseth v. Spellman, 654 F.2d 1349, 1353 (9th Cir. 28 1981). Pursuant to 28 U.S.C. § 1915(e)(1), “[t]he court may request an attorney 1 to represent any person unable to afford counsel.” However, the court will 2 appoint counsel for indigent civil litigants only in “exceptional circumstances.” 3 Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009) (§ 1983 action). “When 4 determining whether ‘exceptional circumstances’ exist, a court must consider 5 ‘the likelihood of success on the merits as well as the ability of the petitioner to 6 articulate his claims pro se in light of the complexity of the legal issues involved.” 7 Id. “Neither of these considerations is dispositive and instead must be viewed 8 together.” Id. 9 The Court denied Plaintiff’s previously filed motion for appointment of 10 counsel without prejudice. (ECF No. 29 at 13). Plaintiff’s renewed motion for 11 appointment of counsel appears to be identical to his previously filed motion. 12 (ECF Nos. 3, 35.) Because the Plaintiff’s renewed motion does not add any 13 additional information or argument for appointment of counsel, the Court again 14 does not find exceptional circumstances to support appointment of counsel, and 15 the Court again denies the motion without prejudice. 16 B. Motions for a Hearing and Reconsideration 17 Prior to the Court issuing its screening order, Plaintiff filed six motions for 18 a preliminary injunction or temporary restraining order, largely alleging that 19 Plaintiff was in danger due to potential retaliation from guards at Ely State Prison 20 (“ESP”). (ECF Nos. 6, 7, 10, 11, 25, 26). In the Court’s screening order, the Court 21 denied all these motions because they are based on claims that are not pled in 22 the first amended complaint. (ECF No. 29 at 12-13). 23 Plaintiff has filed three motions requesting that the Court schedule a 24 hearing to address conditions at ESP and reconsider the denial of his previously 25 filed motions for a temporary restraining order or preliminary injunction. (ECF 26 Nos. 34, 37, 39). A motion to reconsider must set forth “some valid reason why 27 the court should reconsider its prior decision” and set “forth facts or law of a 28 strongly convincing nature to persuade the court to reverse its prior decision.” 1 Frasure v. United States, 256 F.Supp.2d 1180, 1183 (D. Nev. 2003). 2 Reconsideration is appropriate if this Court “(1) is presented with newly 3 discovered evidence, (2) committed clear error or the initial decision was 4 manifestly unjust, or (3) if there is an intervening change in controlling law.” Sch. 5 Dist. No. 1J v. Acands, Inc., 5 F.3d 1255, 1263 (9th Cir. 1993). “A motion for 6 reconsideration is not an avenue to re-litigate the same issues and arguments 7 upon which the court already has ruled.” Brown v. Kinross Gold, U.S.A., 378 8 F.Supp.2d 1280, 1288 (D. Nev. 2005). 9 The Court does not find good reason to reconsider its decision denying 10 Plaintiff’s previously filed motions for a preliminary injunction or temporary 11 restraining order. As the Court explained in its screening order, injunctive relief, 12 whether temporary or permanent, is an “extraordinary remedy, never awarded as 13 of right.” Winter v. Natural Res. Defense Council, 555 U.S. 7, 24 (2008). “A plaintiff 14 seeking a preliminary injunction must establish that he is likely to succeed on 15 the merits, that he is likely to suffer irreparable harm in the absence of 16 preliminary relief, that the balance of equities tips in his favor, and that an 17 injunction is in the public interest.” Am. Trucking Ass’ns, Inc. v. City of Los 18 Angeles, 559 F.3d 1046, 1052 (9th Cir. 2009) (quoting Winter, 555 U.S. at 20). 19 Furthermore, under the Prison Litigation Reform Act (“PLRA”), preliminary 20 injunctive relief must be “narrowly drawn,” must “extend no further than 21 necessary to correct the harm,” and must be “the least intrusive means necessary 22 to correct the harm.” 18 U.S.C. § 3626(a)(2). “A court's equitable power lies only 23 over the merits of the case or controversy before it. When a plaintiff seeks 24 injunctive relief based on claims not pled in the complaint, the court does not 25 have the authority to issue an injunction.” Pac. Radiation Oncology, LLC v. 26 Queen's Med. Ctr., 810 F.3d 631, 633 (9th Cir. 2015) (emphasis added). 27 The Court denied Plaintiff’s previously filed motions for a preliminary 28 injunction or temporary restraining order because they all dealt with claims of 1 ongoing retaliation and danger from prison guards at ESP. In this case, Plaintiff 2 brings an excessive use of force claim about an incident at LCC, as well as a claim 3 of deliberate indifference to a serious medical need regarding the injury that he 4 suffered from the excessive use of force. (ECF No. 29 at 4-10). The first amended 5 complaint does not include any claims regarding retaliation from prison guards 6 at ESP or danger of being attacked. 7 In his motion for an emergency hearing, Plaintiff notes that in this motion 8 for leave to file a first amended complaint, he referenced retaliation and threats 9 from ESP staff, and he stated that he was not pursuing those claims because he 10 feared further retaliation. (ECF No. 37 at 3). He also states that in his first 11 amended complaint he stated that he was at risk of substantial irreparable harm. 12 (Id.) Plaintiff argues that these references to retaliation and potential harm are 13 sufficient to give the Court the power to hear his requests for a preliminary 14 injunction regarding retaliation from ESP guards. (Id.) 15 Plaintiff is mistaken.

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Related

Larry A. Storseth, 623435 v. John D. Spellman
654 F.2d 1349 (Ninth Circuit, 1981)
Palmer v. Valdez
560 F.3d 965 (Ninth Circuit, 2009)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Frasure v. United States
256 F. Supp. 2d 1180 (D. Nevada, 2003)
Federal Deposit Ins. Corp. v. Grant
8 F. Supp. 2d 1275 (N.D. Oklahoma, 1998)

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Anderson v. Ely State Prison, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-ely-state-prison-nvd-2025.