DeLeon v. Pierce County Jail

CourtDistrict Court, W.D. Washington
DecidedNovember 29, 2022
Docket3:22-cv-05473
StatusUnknown

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

Bluebook
DeLeon v. Pierce County Jail, (W.D. Wash. 2022).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 JOSE RAFAEL DELEON, CASE NO. 3:22-CV-5473-TSZ-DWC 11 Plaintiff, ORDER DECLINING TO SERVE AND 12 v. GRANTING LEAVE TO FILE AMENDED COMPLAINT 13 PIERCE COUNTY JAIL, et al.,

14 Defendant.

15 16 Plaintiff Jose Rafael De Leon, proceeding pro se and in forma pauperis, filed this civil 17 rights complaint under 42 U.S.C. § 1983. Having reviewed and screened plaintiff’s complaint 18 under 28 U.S.C. § 1915A, the Court declines to serve plaintiff’s complaint but provides plaintiff 19 leave to file an amended pleading by December 27, 2022 to cure the deficiencies identified 20 herein. 21 I. Background 22 Plaintiff, a pretrial detainee at the Pierce County Jail, asserts numerous claims against 23 defendants Pierce County Jail, Pierce County Sheriff Department and “Pierce County 24 Jail/Naphcare.” Dkt. 1-1 at 3. Plaintiff alleges defendants violated his constitutional rights by: (1) 1 providing inadequate spacing between bunks; (2) violating plaintiff’s right to speedy trial; (3) 2 denying adequate access to criminal defense counsel; (4) refusing to provide contact information 3 for the federal courthouse; (5) failing to feed plaintiff lunch on one occasion; (6) using trustee 4 inmate workers untrained in proper handling of hazardous substances or COVID-19 protocols;

5 (7) using improperly trained trustee inmate workers for food handling; and (8) opening legal and 6 “federal” mail. 7 Plaintiff also purports to bring several of his claims (Claims 1, 2, 3, 4, 5) on behalf of 8 himself and unnamed “others.” Dkt. 1-1 at 4, 6, 7, 9. 9 II. Discussion 10 Under the Prison Litigation Reform Act of 1995, the Court is required to screen 11 complaints brought by prisoners seeking relief against a governmental entity or officer or 12 employee of a governmental entity. 28 U.S.C. § 1915A(a). The Court must “dismiss the 13 complaint, or any portion of the complaint, if the complaint: (1) is frivolous, malicious, or fails to 14 state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant

15 who is immune from such relief.” Id. at (b); 28 U.S.C. § 1915(e)(2); see Barren v. Harrington, 16 152 F.3d 1193 (9th Cir. 1998). 17 To state a claim for relief under 42 U.S.C. § 1983, a plaintiff must show: (1) he suffered a 18 violation of rights protected by the Constitution or created by federal statute, and (2) the 19 violation was proximately caused by a person acting under color of state law. See Crumpton v. 20 Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). The first step in a § 1983 claim is therefore to 21 identify the specific constitutional right allegedly infringed. Albright v. Oliver, 510 U.S. 266, 271 22 (1994). 23

24 1 To satisfy the second prong, a plaintiff must allege facts showing how individually 2 named defendants caused, or personally participated in causing, the harm alleged in the 3 complaint. See Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988); Arnold v. Int’l Bus. Machines 4 Corp., 637 F.2d 1350, 1355 (9th Cir. 1981). A person subjects another to a deprivation of a

5 constitutional right when committing an affirmative act, participating in another’s affirmative act, 6 or omitting to perform an act which is legally required. Johnson v. Duffy, 588 F.2d 740, 743 (9th 7 Cir. 1978). Sweeping conclusory allegations against an official are insufficient to state a claim for 8 relief. Leer, 844 F.2d at 633. Further, a § 1983 suit cannot be based on vicarious liability alone, but 9 must allege the defendant’s own conduct violated the plaintiff’s civil rights. City of Canton, Ohio 10 v. Harris, 489 U.S. 378, 385–90 (1989). 11 A. Improper Defendants 12 Plaintiff names only three defendants: the Pierce County Jail, the Pierce County Sheriff 13 Department, and “Pierce County Jail/Naphcare.” But the Pierce County Jail and Pierce County 14 Sheriff Department are not legal entities capable of being sued under § 1983. Rather, the proper

15 defendant would be the municipality, Pierce County. See Monell v. New York City Dept. of Soc. 16 Servs. of City of New York, 436 U.S. 658, 690 (1978); Wright v. Clark Cnty. Sheriff’s Off., No. 17 3:15-cv-05887 BHS JRC, 2016 WL 1643988, *2 (W.D. Wash. April 26, 2016). Additionally, 18 when a private entity acting under color of state law is sued pursuant to § 1983, the Ninth Circuit 19 has instructed that the Monell requirements apply to the private entity. Tsao v. Desert Palace, 20 Inc., 698 F.3d 1128, 1138–39 (9th Cir. 2012); see also M.H. v. County of Alameda, 62 F. Supp. 21 3d 1049, 1085–86 (N.D. Cal. 2014) (finding a private healthcare provider fell under Monell). 22 To set forth a claim against a municipality or entity pursuant to Monell, a plaintiff must 23 show the defendant’s employees or agents acted through an official custom, pattern, or policy

24 permitting deliberate indifference to, or violating, the plaintiff’s civil rights, or that the entity 1 ratified the unlawful conduct. Monell, 436 U.S. at 690–91. A plaintiff must show (1) deprivation 2 of a constitutional right; (2) the municipality or entity has a policy; (3) the policy amounts to 3 deliberate indifference to a plaintiff’s constitutional rights; and (4) the policy is the moving force 4 behind the constitutional violation. See Oviatt v. Pearce, 954 F.2d 1470, 1474 (9th Cir. 1992).

5 A municipality “cannot be held liable solely because it employs a tortfeasor—or, in other 6 words, a municipality cannot be held liable under § 1983 on a respondeat superior theory.” 7 Monell, 436 U.S. at 691 (emphasis in original). Similarly, mere negligence in training employees 8 cannot support municipal liability; instead, plaintiff must allege facts demonstrating the failure to 9 train amounts to deliberate indifference to the rights of those who deal with municipal 10 employees. City of Canton, 489 U.S. at 388–89. Finally, a single incident of unconstitutional 11 action is generally insufficient to state a claim for municipal liability. Benavidez v. Cnty. of San 12 Diego, 993 F.3d 1134, 1154 (9th Cir. 2021). 13 Plaintiff has not named Pierce County as a defendant and has also not alleged facts to 14 show Pierce County or Naphcare is liable under Monell. See Dkt. 1-1. If plaintiff seeks to sue

15 Pierce County, he must name Pierce County as a defendant. Furthermore, plaintiff must allege 16 facts sufficient to meet the required elements of a claim pursuant to Monell and show Pierce 17 County or Naphcare violated his constitutional rights. 18 B. Personal Participation 19 Plaintiff’s claims also fail to allege the personal participation of any defendant in the 20 alleged violations of his rights. Indeed, with respect to defendant Naphcare, plaintiff makes no 21 allegations of any conduct or wrongdoing by Naphcare and therefore states no claim against it.

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DeLeon v. Pierce County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/deleon-v-pierce-county-jail-wawd-2022.