French v. Wallahan

CourtDistrict Court, N.D. California
DecidedFebruary 1, 2022
Docket3:21-cv-09446
StatusUnknown

This text of French v. Wallahan (French v. Wallahan) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
French v. Wallahan, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JADE FRENCH, Case No. 21-cv-09446-SI

8 Plaintiff, ORDER GRANTING MOTION TO 9 v. DISMISS

10 M. WALLAHAN, et al., Re: Dkt. No. 16 11 Defendants.

12 13 Before the Court is a motion to dismiss filed by defendants L. Brabec, J. Mills, and M. 14 Wallahan pursuant to Fed. R. Civ. P. 12(b)(6). Dkt. No. 9 (filed on December 16, 2021). Because 15 plaintiff’s complaint fails to allege a plausible basis for relief, the Court GRANTS the motion and 16 dismisses the complaint with leave to amend on or before February 18, 2022. The hearing scheduled 17 for February 4, 2022 is hereby VACATED pursuant to Civil Local Rule 7-1(b), as oral argument is 18 not required to resolve this matter. 19 20 BACKGROUND1 21 Jade French states that while being held as a pretrial detainee at the Lake County Jail, he was 22 “deprived of [his] liberty, freedom and almost [his] life.” Dkt. No. 1 at 6 (Complaint and Notice of 23 Removal). On the morning of December 7, 2020, plaintiff awoke in his cell to the sound of “roof 24 torching” work being done overhead. Id. (“Roof torching” usually entails waterproofing a roof by 25 adhering bitumen membranes onto the surface with a propane torch). Plaintiff soon noticed noxious 26 fumes from the roofing activities enter his cell through ventilation ducts, resulting in a burning 27 1 sensation in his nose, lungs, eyes, and throat. Id. At that time, fearing “the possibility of a fire,” 2 plaintiff alerted nearby jailhouse guards, who assured him that everything “was ok” as “they were 3 just doing roof work.” Plaintiff then stuffed toilet paper into the vents to block further exposure. 4 Id. One of the guards walked up to plaintiff’s cell to ask why he was stuffing toilet paper in the 5 vents; plaintiff informed her that he was “defending” himself. Id. at 7. 6 A few hours later, plaintiff’s girlfriend arrived to bail him out on bond. Id. While waiting 7 for plaintiff’s release to be processed, plaintiff’s girlfriend observed roofers working directly above 8 plaintiff’s cell for several hours. Id. The next day, after being released, plaintiff went to an 9 emergency room as his “lungs were damaged and [he] felt badly…[and] lost [his] voice for a week 10 afterwards.” Id. at 9. As plaintiff puts it, he was “subjected to noxious, carcinogenic lethal gasses 11 in a small very confined area,” and he “warned everyone and nobody did anything to assure [his] 12 safety.” Id. at 7. 13 Appearing pro se in October 2021, plaintiff filed suit in the County of Lake Superior Court 14 against defendants L. Brabec, J. Mills, and M. Wallahan – the alleged jailhouse guards who were 15 present on December 7, 2020. Plaintiff’s claims are based on the Eighth Amendment (inhumane 16 conditions), the Fourteenth Amendment (due process and equal protection), and state tort law 17 (intentional infliction of emotional distress). 18 Because plaintiff alleged federal claims against state actors under 28 U.S.C. § 1983, 19 defendants removed the case to this Court on December 7, 2021.2 Defendants filed the instant 20 motion to dismiss on December 17, 2021. Dkt. No. 9. Plaintiff failed to file an opposition to the 21 motion to dismiss by December 30, 2021, the deadline set by the Court, and has not filed a response 22 as of this date. 23 24 LEGAL STANDARD 25 To survive a motion to dismiss under 12(b)(6), a complaint must allege “enough facts to 26 state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 27 1 (2007). While courts do not require “heightened fact pleading of specifics,” a plaintiff must allege 2 facts sufficient to “raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555, 3 570. A court must accept as true all factual allegations in a complaint but need not accept as true 4 “threadbare recitals” of a claim’s legal elements. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Even 5 pro se plaintiffs must satisfy the plausibility standard, Ivey v. Bd. of Regents of Univ. of Alaska, 673 6 F.2d 266, 268 (9th Cir. 1982), although the court shall “construe the pleadings liberally and [] afford 7 the [pro se plaintiff] the benefit of any doubt.” Bretz v. Kelman, 773 F.2d 1026, 1027 n.1 (9th Cir. 8 1985) (en banc). 9 DISCUSSION 10 11 I. Eighth Amendment Claim 12 While convicted inmates may assert claims under the Eighth and Fourteenth Amendments, 13 pretrial detainees generally can only assert claims under the Fourteenth Amendment. Redman v. 14 Cty. of San Diego, 942 F.2d 1435, 1441 (9th Cir. 1991), abrogated on other grounds by Perez v. 15 Cox, 788 F. App’x 438, 442 (9th Cir. 2019) (“while the eighth amendment proscribes cruel and 16 unusual punishment for convicted inmates, the due process clause of the fourteenth amendment 17 proscribes any punishment of pretrial detainees.”). The complaint indicates plaintiff was a pretrial 18 detainee. Dkt. No. 1 at 7 (stating that his girlfriend came to bail him “out with the bail bondsman.”). 19 Accordingly, plaintiff may not assert an Eighth Amendment violation. 20 Even if the Eighth Amendment were available, a claim for inhumane conditions of 21 confinement requires a detainee to establish that a prison official actually “knows of and disregards 22 an excessive risk to inmate health or safety.” Castro v. Cty. of Los Angeles, 833 F.3d 1060, 1071 23 (9th Cir. 2016) (“the official must both be aware of facts from which the inference could be drawn 24 that a substantial risk of serious harm exists, and he must also draw the inference.”). Plaintiff does 25 not allege facts that render such subjective knowledge plausible. 26 27 II. Fourteenth Amendment Due Process Claim 1 when a failure to protect a detainee from harm “constitutes deliberate indifference to their safety.” 2 Redman, 942 F.2d 1435 at 1441. A “mere lack of due care by a state official” does not “’deprive’ 3 an individual of life, liberty, or property under the Fourteenth Amendment.” Daniels v. Williams, 4 474 U.S. 327, 330-31 (1986) (holding that negligent actions or omissions are not actionable under 5 § 1983). Accordingly, to sufficiently allege a failure-to-protect claim under the Fourteenth 6 Amendment, a pretrial detainee’s complaint must plausibly allege each of the following elements:

7 (i) the defendant made an intentional decision with respect to the conditions under which the 8 plaintiff was confined; (ii) those conditions put the plaintiff at substantial risk of suffering serious harm; 9 (iii) the defendant did not take reasonable available measures to abate that risk, even though a reasonable official in the circumstances would have appreciated the high degree of risk 10 involved—making the consequences of the defendant's conduct obvious; and (iv) by not taking such measures, the defendant caused the plaintiff’s injuries. 11 Gordon v. Cty. of Orange, 888 F.3d 1118, 1125 (9th Cir. 2018).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Daniels v. Williams
474 U.S. 327 (Supreme Court, 1986)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jonathon Castro v. County of Los Angeles
833 F.3d 1060 (Ninth Circuit, 2016)
Mary Gordon v. County of Orange
888 F.3d 1118 (Ninth Circuit, 2018)
Lee v. City of Los Angeles
250 F.3d 668 (Ninth Circuit, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
French v. Wallahan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/french-v-wallahan-cand-2022.