Devin E. Shaffer v. Santa Clara County Sheriff's Office, et al.

District Court, N.D. California·Decided August 11, 2026·No. 5:26-cv-04530·Unknown

Opinion

DEVIN E. SHAFFER, Case No. 26-cv-04530-NW

Plaintiff, ORDER SCREENING COMPLAINT, DISMISSING COMPLAINT WITH v. LEAVE TO AMEND. AND DENYING MOTION FOR LEAVE TO AMEND AS OFFICE, et al., Re: ECF No. 4 Defendants.

Plaintiff Devin Shaffer, a state pretrial detainee, filed a pro se civil rights lawsuit alleging several claims against Santa Clara County Jail staff. See ECF No. 1. On June 11, 2026, Shaffer also filed a motion for leave to amend requesting to change the names of two Defendants. See ECF No. 4. The Complaint is now before the Court for screening pursuant to 28 U.S.C. § 1915A(a). For the reasons set forth below, the Court GRANTS the motion for leave to amend and DISMISSES the Complaint with leave to amend. Shaffer alleges in his Complaint1 that, on several occasions throughout his current incarceration, staff at the Santa Clara County Jail have discarded or improperly seized his personal items, commissary items, and unspecified papers. On one occasion, in November 2024, Shaffer was moved for his safety to another cell; however, after deputies moved his personal belongings, Shaffer noticed that he was missing commissary items such as soap, condiments, food, toothpaste, and “personal papers.” ECF No. 1 at 4. Shaffer estimates that the items were worth approximately $10. In January 2025, Shaffer was again moved to another cell. Deputies Ignacz and Swanson, who were responsible for moving Shaffer’s belongings, allegedly threw away several items, including a bag of coffee, toothpaste, shampoo, condiments, and some first aid items. During another move in April 2026, Defendants Loaiza #1 and Loaiza #22 allegedly lost or discarded bags of rice, coffee, condiments, peanut butter, and some of Shaffer’s hygiene items such as deodorant, combs, hair gel, and soap. Shaffer also alleges that several pieces of his mail, including legal mail from the Court and from counsel, were discarded. Shaffer believes that these items were seized in retaliation for his ongoing federal civil rights lawsuits against employees of the Santa Clara County Sheriff’s Office. He seeks monetary damages. Federal courts engage in a preliminary screening of cases in which prisoners seek redress from a governmental entity or officer, or an 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, 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. at § 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 claim showing that the pleader is entitled to relief.” Although a complaint “does not need detailed 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. 2 In his motion for leave to amend, Shaffer explains that he intended to name Loaiza #1 and Loaiza #2, rather than “Loizano #1” and “Loizano #2,” in his Complaint. ECF No. 4 at 1. at 570. The United States Supreme Court has explained the “plausible on its face” standard of Twombly: “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). 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 42 U.S.C. § 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 Corr. & Rehabilitation, 726 F.3d 1062, 1074 (9th Cir. 2013); Leer v. Murphy, 844 F.2d 628, 634 (9th Cir. 1988). Actions in this context include when a defendant engages in the affirmative act, participates in another’s affirmative act, or fails to perform a legally required act. Leer, 844 F.2d at 633. The Court considers Shaffer’s claims below. A. Loss of Personal Property When a pretrial detainee challenges conditions of his confinement, the proper inquiry is whether the conditions amount to punishment in violation of the Due Process Clause of the Fourteenth Amendment. See Bell v. Wolfish, 441 U.S. 520, 535 n.16 (1979). “To constitute punishment, a government action must (i) harm a detainee and (ii) be intended to punish him.” Houston v. Maricopa Cnty., 116 F.4th 935, 940 (9th Cir. 2024). Because the State must be able to take steps to maintain security and order at pretrial facilities, restrictions and conditions that are reasonably related to a facility’s interest in maintaining jail security and order are not considered to be unconstitutional punishment. See Bell, 441 U.S. at 540. Even liberally construed, Shaffer fails to state a cognizable constitutional claim regarding the alleged seizure or disposal of his personal property. The Court notes that the Supreme Court imposition with which the Constitution is not concerned.” See Bell, 441 U.S. at 539 n.21 (citation modified). Here, Shaffer alleges the removal of unspecified documents, miscellaneous personal and canteen items, and condiment packets after he was moved from one cell to another. While he may be able to pursue a claim in small claims court or some other venue for the improper disposal of these items, he fails to allege any facts showing that Defendants’ disposal of these items caused more than de minimis harm such that his claim implicates his Fourteenth Amendment due process rights. Cf. Keenan v. Hall, 83 F.3d 1083, 1092 (9th Cir. 1996), amended by 135 F.3d 1318 (9th Cir. 1998) (holding that there is no constitutional right to canteen items); Wright v. Gutierrez, No.

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Devin E. Shaffer v. Santa Clara County Sheriff's Office, et al., (N.D. Cal. 2026).

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