Danny Adams v. Santa Rita Jail, et al.

District Court, N.D. California·Decided July 17, 2026·No. 5:25-cv-09928·Unknown

Opinion

DANNY ADAMS, Case No. 25-cv-09928-EKL

Plaintiff, ORDER SCREENING COMPLAINT, v. DEFERRING DISMISSAL, AND SUA SPONTE GRANTING LIMITED SANTA RITA JAIL, et al., DISCOVERY Defendants.

Plaintiff Danny Adams, a pro se state detainee, filed this civil rights action under 42 U.S.C. § 1983, challenging medical care he received while he was housed in Santa Rita Jail in Alameda County. ECF No. 1. The complaint is before the Court for screening pursuant to 28 U.S.C. § 1915A(a). Based on the following reasons, the Court DEFERS DISMISSAL of the complaint and sua sponte GRANTS limited discovery in this matter. A. Standard of Review Federal courts engage in a preliminary screening of cases in which prisoners seek redress from a governmental entity, or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). In its review, the Court must identify any cognizable claims and dismiss any claims that are frivolous or malicious, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. Id. § 1915A(b)(1)-(2). Pro se pleadings must be liberally construed. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the factual allegations, . . . a plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment] to relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do . . . . Factual allegations must be enough to raise a right to relief above the speculative level.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations omitted). A complaint must proffer “enough facts to state a claim to relief that is plausible on its face.” Id. at 570. “While legal conclusions can provide the framework of a complaint, they must be supported by factual allegations. When there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). B. Section 1983 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege that: (1) a right secured by the Constitution or laws of the United States was violated, and (2) the alleged deprivation was committed by a person acting under the color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). Liability may be imposed on an individual defendant under Section 1983 if the plaintiff can show that the defendant’s actions actually and proximately caused the deprivation of a federally protected right. Lemire v. Cal. Dep’t of Corrections & Rehabilitation, 726 F.3d 1062, 1074 (9th Cir. 2013); Leer v. Murphy, 844 F.2d 628, 634 (9th Cir. 1988). A person deprives another of a constitutional right within the meaning of Section 1983 if he does an affirmative act, participates in another’s affirmative act, or fails to perform an act that he is legally required to do, causing the deprivation of which the plaintiff complains. Leer, 844 F.2d at 633. In his complaint, Adams alleges that sometime in 2025, while he was housed at Santa Rita Jail, he received a biopsy on his shoulder at an unspecified medical facility. See ECF No. 1 at 2. After he was transferred back to Santa Rita Jail, Adams began feeling “extrem[e]ly sick,” leading him to believe that the wound was infected. Id. Adams reportedly told nurses about the issue, and eventually the biopsy wound “spread” and Adams “felt like [he] was gonna die.” Id. Although Adams repeatedly complained about the issue, Santa Rita Jail staff refused to refer Adams to an staff had to send Adams to the emergency room, where Adams states he nearly died. Id. at 2-3. Adams seeks monetary damages. Id. at 4. For claims of deliberate indifference to a prisoner’s medical needs, the applicable constitutional standard depends on whether the plaintiff has been convicted of a crime at the time of the challenged conduct. See Castro v. Cnty. Of Los Angeles, 833 F.3d 1060, 1067-68 (9th Cir. 2016). Here, it is not clear from Adams’ filings whether he was a pretrial detainee or had been convicted at the time of the alleged incident. If the incident occurred while he was a pretrial detainee, his claim arises under the Fourteenth Amendment’s due process clause. If Adams was serving a criminal sentence at the time of the incident, his claim arises under the Eighth Amendment’s cruel and unusual punishment clause. Under the Fourteenth Amendment, a pretrial detainee seeking to bring a medical care claim against a defendant must demonstrate:

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Danny Adams v. Santa Rita Jail, et al., (N.D. Cal. 2026).

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