Elliott v. Caballero

District Court, N.D. California·Decided November 18, 2019·No. 4:19-cv-06005·Unknown

Opinion

AARON ELLIOTT, Case No. 19-cv-06005-PJH

Plaintiff, ORDER OF DISMISSAL WITH LEAVE v. TO AMEND

J. CABALLERO, et al., Defendants.

Plaintiff, a state prisoner, has filed a pro se civil rights complaint under 42 U.S.C. § 1983. He has been granted leave to proceed in forma pauperis. Plaintiff filed an original complaint (Docket No. 1) and then an amended complaint (Docket No. 8). The court has reviewed the amended complaint. Federal courts must 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 which 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." "Specific facts are not is and the grounds upon which it rests."'" Erickson v. Pardus, 551 U.S. 89, 93 (2007) (citations omitted). Although in order to state a claim 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 Atlantic 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. The United States Supreme Court has recently 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 two essential elements: (1) that a right secured by the Constitution or laws of the United States was violated, and (2) that the alleged deprivation was committed by a person acting under the color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). Plaintiff alleges that he was improperly found guilty of several false disciplinary violations in retaliation for his protected conduct. The Due Process Clause of the Fourteenth Amendment of the U.S. Constitution protects individuals against governmental deprivations of life, liberty or property without due process of law. Interests that are procedurally protected by the Due Process Clause may arise from two sources: the Due Process Clause itself and laws of the states. See Meachum v. Fano, 427 U.S. 215, 224-27 (1976). In the prison context, these interests are generally ones pertaining to liberty. Changes in conditions so severe as to affect the sentence imposed in an unexpected manner implicate the Due Process Clause itself, 484 (1995) (citing Vitek v. Jones, 445 U.S. 480, 493 (1980) (transfer to mental hospital), and Washington v. Harper, 494 U.S. 210, 221-22 (1990) (involuntary administration of psychotropic drugs)). Deprivations that are less severe or more closely related to the expected terms of confinement may also amount to deprivations of a protected liberty interest, provided that the liberty in question is one of “real substance.” See Sandin, 515 U.S. at 477-87. An interest of “real substance” will generally be limited to freedom from restraint that imposes an “atypical and significant hardship on the inmate in relation to the ordinary incidents of prison life” or “will inevitably affect the duration of [a] sentence.” Id. at 484, 487. The placement of an inmate in a highly restrictive housing setting may amount to a deprivation of a liberty interest of “real substance” within the meaning of Sandin. See Wilkinson v. Austin, 545 U.S. 209, 224 (2005). When there is a deprivation of a liberty interest of real substance, the procedural protections to which the prisoner is entitled depend on whether the deprivation results from a disciplinary decision or an administrative decision. If it is a disciplinary decision, the procedural protections required are: written notice, time to prepare for the hearing, a written statement of decision, allowance of witnesses and documentary evidence when not unduly hazardous, and aid to the accused where the inmate is illiterate or the issues are complex. Wolff v. McDonnell, 418 U.S. 539, 564-67 (1974). The Due Process Clause requires only that prisoners be afforded those procedures mandated by Wolff and its progeny; it does not require that prisons comply with their own, more generous procedures. See Walker v. Sumner, 14 F.3d 1415, 1419–20 (9th Cir. 1994), overruled on other grounds by Sandin v. Connor, 515 U.S. 472. A prisoner's right to due process is violated “only if he [is] not provided with process sufficient to meet the Wolff standard.” Id. at 1420. There also must be some reliable evidence to support the disciplinary decision, see Superintendent v. Hill, 472 U.S. 445, 454 (1985); Cato v. Rushen, 824 F.2d 703, 704-05 (9th Cir. 1987). “Ascertaining whether [the some evidence] standard is satisfied credibility of witnesses, or weighing of the evidence. Instead, the relevant question is whether there is any evidence in the record that could support the conclusion reached” by the disciplinary hearing officer. Superintendent v. Hill, 472 U.S. at 455-56. This standard is considerably lower than that applicable in criminal trials. See id. at 456. “Within the prison context, a viable claim of First Amendment retaliation entails five basic elements: (1) An assertion that a state actor took some adverse action against an inmate (2) because of (3) that prisoner's protected conduct, and that such action (4) chilled the inmate's exercise of his First Amendment rights, and (5) the action did not reasonably advance a legitimate correctional goal.” Rhodes v. Robinson, 408 F.3d 559

Elliott v. Caballero, (N.D. Cal. 2019).

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Related

Wolff v. McDonnell
418 U.S. 539 (Supreme Court, 1974)
Meachum v. Fano
427 U.S. 215 (Supreme Court, 1976)
Vitek v. Jones
445 U.S. 480 (Supreme Court, 1980)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Washington v. Harper
494 U.S. 210 (Supreme Court, 1990)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Michael Hanrahan v. Michael P. Lane
747 F.2d 1137 (Seventh Circuit, 1984)
Michael Henry Ferdik v. Joe Bonzelet, Sheriff
963 F.2d 1258 (Ninth Circuit, 1992)
Rhodes v. Robinson
408 F.3d 559 (Ninth Circuit, 2005)
Wilkinson v. Austin
545 U.S. 209 (Supreme Court, 2005)
Smith v. Mensinger
293 F.3d 641 (Third Circuit, 2002)
Hines v. Gomez
108 F.3d 265 (Ninth Circuit, 1997)
Cato v. Rushen
824 F.2d 703 (Ninth Circuit, 1987)