Ayarzagoitia v. Christensen

CourtDistrict Court, D. Idaho
DecidedJanuary 16, 2020
Docket1:19-cv-00284
StatusUnknown

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

Bluebook
Ayarzagoitia v. Christensen, (D. Idaho 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

DAMIAN AYARZAGOITIA, Case No. 1:19-cv-00284-DCN Plaintiff, INITIAL REVIEW ORDER v.

JAY CHRISTENSEN and BRAD LITTLE,

Defendants.

The Clerk of Court conditionally filed Plaintiff Damian Ayarzagoitia’s Complaint as a result of Plaintiff’s status as an inmate and in forma pauperis request. Plaintiff has since filed an Amended Complaint.1 See Dkt. 7. The Court now reviews the Amended Complaint to determine whether it or any of the claims contained therein should be summarily dismissed under 28 U.S.C. §§ 1915 and 1915A. Having reviewed the record, and otherwise being fully informed, the Court enters the following Order. 1. Screening Requirement The Court must review complaints filed by prisoners seeking relief against a governmental entity or an officer or employee of a governmental entity, as well as complaints filed in forma pauperis, to determine whether summary dismissal is appropriate. The Court must dismiss a complaint or any portion thereof that states a frivolous or

1 After filing his Amended Complaint, Plaintiff also filed a second amended complaint that omitted claims against Defendant Christensen. Plaintiff has since moved to withdraw the second amended complaint, and the Court will grant the motion. Therefore, the Court reviews the Amended Complaint (Dkt. 7) as the operative complaint in this case and will reinstate Jay Christensen as a named defendant. malicious claim, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) & 1915A(b).

2. Pleading Standard A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A complaint fails to state a claim for relief under Rule 8 if the factual assertions in the complaint, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is

liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. In other words, although Rule 8 “does not require detailed factual allegations, ... it demands more than an unadorned, the-defendant-unlawfully- harmed-me accusation.” Id. (internal quotation marks omitted). If the facts pleaded are

“merely consistent with a defendant’s liability,” or if there is an “obvious alternative explanation” that would not result in liability, the complaint has not stated a claim for relief that is plausible on its face. Id. at 678, 682 (internal quotation marks omitted). 3. Factual Allegations Plaintiff is a prisoner in the custody of the Idaho Department of Correction (“IDOC”). He is currently incarcerated at Eagle Pass Correctional Facility (“EPCF”) in

Eagle Pass, Texas. EPCF is operated by a private prison company that has contracted with the IDOC for the housing of Idaho prisoners. Plaintiff was transferred to EPCF from the Idaho State Correctional Center (“ISCC”) in October 2018. See Compl., Dkt. 7, at 2. Plaintiff contends that, before his transfer to EPCF, he sent a concern form to Defendant Christensen, the warden at ISCC, stating that Plaintiff had a “green light” placed against him by two prison gangs—the Aryan Knights (“AK”) and the Severely Violent

Criminals (“SVC”). Id. A green light means that every gang member is tasked with attacking the green-lit inmate on sight. Id. Knowing that members of these gangs were housed at EPCF, Plaintiff told Defendant Christensen it would not be safe for him to be transferred. Despite these concerns, Plaintiff was transferred to EPCF on October 9, 2018. That

same day, Plaintiff was attacked by prison gang members and suffered serious injury. Id. at 2–3. Plaintiff later told the Director of the IDOC about the attack, but “nothing has happened to fix the issue.” Id. at 3. In May 2019, Plaintiff was placed in protective custody at EPCF, but he believes he is “still at risk of serious physical injury.” Id. Plaintiff claims that Defendant Christensen’s inaction, which permitted Plaintiff’s

transfer to EPCF, violated the Eighth Amendment and Idaho Code § 20-241A. Id. at 2–5. Plaintiff also asserts claims against Idaho Governor Brad Little. He contends that Idaho Code §§ 20-209H, 20-209(3) and (4), and 20-241A are unconstitutional as violating the Eighth or Fourteenth Amendments. Id. at 6–8. Plaintiff also asserts that Idaho Code § 20-209H violates other Idaho statutes—specifically, Idaho Code §§ 19-5305(1) and (2),

19-4708(1) and (2)(c), and 19-4707. Id. 4. Section 1983 Claims A. Standards of Law Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To state a

plausible civil rights claim, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). To be liable under § 1983, “the defendant must possess a purposeful, a knowing, or possibly a reckless state of mind.” Kingsley v. Hendrickson, 135 S. Ct. 2466, 2472 (2015). Negligence is not actionable under § 1983, because a negligent act by a public official is not an abuse

of governmental power but merely a “failure to measure up to the conduct of a reasonable person.” Daniels v. Williams, 474 U.S. 327, 332 (1986). Prison officials generally are not liable for damages in their individual capacities under § 1983 unless they personally participated in the alleged constitutional violations. Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989); see also Iqbal, 556 U.S. at 677 (“[E]ach

Government official, his or her title notwithstanding, is only liable for his or her own misconduct.”). Section 1983 does not allow for recovery against an employer or principal simply because an employee or agent committed misconduct. Taylor, 880 F.2d at 1045. However, “[a] defendant may be held liable as a supervisor under § 1983 ‘if there exists ... a sufficient causal connection between the supervisor’s wrongful conduct and the

constitutional violation.’” Starr v. Baca, 652 F.3d 1202, 1207 (9th Cir. 2011) (quoting Hansen v. Black, 885 F.2d 642, 646 (9th Cir. 1989)). A plaintiff can establish this causal connection by alleging that a defendant (1) “set[] in motion a series of acts by others”; (2) “knowingly refus[ed] to terminate a series of acts by others, which [the supervisor] knew or reasonably should have known would cause

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Ayarzagoitia v. Christensen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ayarzagoitia-v-christensen-idd-2020.