Ericsson v. Anderson

CourtDistrict Court, D. Idaho
DecidedJanuary 11, 2023
Docket3:22-cv-00297
StatusUnknown

This text of Ericsson v. Anderson (Ericsson v. Anderson) 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
Ericsson v. Anderson, (D. Idaho 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

GUNNAR BJORN ERICSSON, Case No. 3:22-cv-00297-DCN Plaintiff, INITIAL REVIEW ORDER BY v. SCREENING JUDGE

DEPUTY WARDEN AMY B. ANDERSON and WARDEN TEREMA D. CARLIN,

Defendants.

The Clerk of Court conditionally filed Plaintiff Gunnar Bjorn Ericsson’s Complaint as a result of Plaintiff’s status as an inmate and in forma pauperis request. The Court now reviews the Complaint to determine whether it should be summarily dismissed in whole or in part under 28 U.S.C. §§ 1915 and 1915A. Having reviewed the record, and otherwise being fully informed, the Court enters the following Order directing Plaintiff to file an amended complaint if Plaintiff intends to proceed. 1. Pleading Standards and Screening Requirement 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). Under modern pleading standards, Rule 8 requires a complaint to “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Iqbal/Twombly “facial plausibility” standard is met when a complaint contains “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). “[D]etailed factual allegations” are not required, but a plaintiff must offer “more than ... unadorned, the-defendant-unlawfully-

harmed-me accusation[s].” 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). Bare allegations that amount to a mere restatement of the elements of a

cause of action, without adequate factual support, are not enough. The Prison Litigation Reform Act (“PLRA”)1 requires that the Court 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 any claims

that do not have adequate factual support or are frivolous or malicious. 28 U.S.C. §§ 1915(e)(2) & 1915A. The Court also must dismiss claims that fail to state a claim upon which relief may be granted or that seek monetary relief from a defendant who is immune from such relief. Id. These last two categories—together with claims that fall outside a federal court’s

narrow grant of jurisdiction—encompass those claims that might, or might not, have factual support but nevertheless are barred by a well-established legal rule.

1 Pub. L. No. 104-134, 110 Stat. 1321, as amended, 42 U.S.C. § 1997e, et seq. The Court liberally construes the pleadings to determine whether a case should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a constitutional

claim, however inartfully pleaded, has an arguable factual and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989) (discussing Federal Rule of Civil Procedure 12(b)(6)), superseded by statute on other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000) (stating that Rule 12(b)(6) authority to dismiss claims was expanded by the PLRA, giving courts power to dismiss deficient claims, sua sponte, before

or after opportunity to amend). 2. Factual Allegations Plaintiff is a prisoner in the custody of the Idaho Department of Correction, currently incarcerated at the Idaho Correctional Institution in Orofino, Idaho. Plaintiff claims that, in retaliation for Plaintiff’s use of the prison grievance process, Defendant

Anderson ordered a targeted search of Plaintiff’s cell. Compl., Dkt. 3, at 2. Correctional officers confiscated Plaintiff’s image catalogs. Id. Unidentified mailroom officers also denied Plaintiff access to other image catalogs. It appears that although inmates are not allowed to possess photos, the catalog images were on standard white paper and therefore, according to Plaintiff, were “within policy.” Id. at 2–3.

Plaintiff filed grievances on the subject and contends the grievances were improperly dismissed or denied. Id. Plaintiff states that, after he filed these grievances, the warden continued to “subject[] [Plaintiff] to retaliation” for using the grievance process. However, Plaintiff does not identify any particular adverse action taken by any Defendant after Plaintiff complained about the confiscation of his materials. Id. at 3. Officers responding to Plaintiff’s grievances described the images as “photos,” and the confiscation sheet for the image catalogs classifies them as “Thumbnails.” Dkt. 3-1 at

2, 8. Plaintiff was informed that the images “were destroyed more than 45 days after the confiscation per Policy.” Id. at 8. Plaintiff asserts that Defendants’ conduct violated of the First Amendment and the Due Process Clause of the Fourteenth Amendment.2 Compl. at 2–3. 3. Discussion

Plaintiff has not stated a claim upon which relief may be granted. The Court will, however, grant Plaintiff 60 days to amend the Complaint. Any amended complaint should take into consideration the following. A. Section 1983 Claims 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). 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

2 Plaintiff also cites the Fifth Amendment’s Due Process Clause. That Clause, however, applies only as against federal, not state, government actors. Thus, the Fifth Amendment’s due process protections are not implicated by the allegations in the Complaint. misconduct.”).

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Ericsson v. Anderson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ericsson-v-anderson-idd-2023.