Garcia v. Idaho State Correction Center

CourtDistrict Court, D. Idaho
DecidedMay 1, 2020
Docket1:20-cv-00001
StatusUnknown

This text of Garcia v. Idaho State Correction Center (Garcia v. Idaho State Correction Center) 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
Garcia v. Idaho State Correction Center, (D. Idaho 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

VINCENT DANIEL GARCIA,

Plaintiff, Case No. 1:20-cv-00001-DCN

vs. INITIAL REVIEW ORDER BY SCREENING JUDGE IDAHO STATE CORRECTIONAL CENTER, G-BLOCK CORRECTION OFFICERS, IDAHO DEPARTMENT OF CORRECTION, STATE OF IDAHO, JAY CHRISTENSEN, and ADAM MILLER,

Defendants.

The Complaint of Plaintiff Vincent Daniel Garcia was conditionally filed by the Clerk of Court due to his status as a prisoner and pauper. (Dkts. 3, 1.) A “conditional filing” means that Plaintiff must obtain authorization from the Court to proceed. All prisoner and pauper complaints seeking relief against a government entity or official must be screened by the Court to determine whether summary dismissal is appropriate. 28 U.S.C. §§ 1915 & 1915A. The Court must dismiss any claims that state a frivolous or malicious claim, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). After reviewing the Complaint, the Court has determined that Plaintiff will be permitted to proceed in a limited manner. REVIEW OF COMPLAINT 1. Factual Allegations On May 6, 2019, Plaintiff was a prisoner in custody of the Idaho Department of

Correction (IDOC), residing at the Idaho State Correctional Center (ISCC). He was taking a walk on close custody maximum Tier G-1, when an STG gang member attacked him. Plaintiff was knocked unconscious for 20 minutes, was in a coma for a month, suffered broken facial bones that had to repaired with screws, developed a seizure disorder, suffered brain damage, and lost his eyesight as a result of the attack.

Plaintiff asserts that the entire incident was captured on video, and that six to eight correctional officers did nothing or not enough to stop the attack and mitigate Plaintiff’s injuries. In response to Plaintiff’s grievance, prison officials asserted that the place he was attacked had low visibility. This fact may cut against them if Plaintiff can show that they knew of, or should have discovered, but failed to remedy the low visibility area. Plaintiff

also asserts that inmates often select a shift change to proceed with an attack. He does not assert whether prison officials knew that. Plaintiff asserts federal civil rights and state law negligence claims. He seeks monetary damages and medical treatment. 2. Standard of Law

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). A complaint fails to state a claim for relief under Rule 8 if the factual assertions in the complaint, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Plaintiffs are required to state facts, and not just legal theories, in a complaint. See Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 556 U.S. at

678. In Iqbal, the Court made clear that “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. at 678. In other words, Federal Rule of Civil Procedure 8 “demands more than an unadorned, the-defendant- unlawfully-harmed-me accusation.” Id. (internal quotation marks omitted). If the facts pleaded are “merely consistent with a defendant’s liability,” the complaint has not stated a

claim for relief that is plausible on its face. Id. (internal quotation marks omitted). Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To state a claim under § 1983, 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). For

Plaintiff’s purposes, 42 U.S.C. § 1983 is an implementing statute that makes it possible to bring a cause of action under the Amendments of the United States Constitution. The Eighth Amendment to the United States Constitution protects prisoners who are convicted felons against cruel and unusual punishment. To state a claim under the Eighth Amendment, Plaintiff must state facts showing that he is “incarcerated under

conditions posing a substantial risk of serious harm,” or that he has been deprived of “the minimal civilized measure of life’s necessities” as a result of Defendants’ actions. Farmer v. Brennan, 511 U.S. 825, 834 (1994) (internal quotation marks omitted). Plaintiff must also allege facts showing that Defendants were deliberately indifferent to his needs. “[D]eliberate indifference entails something more than mere negligence, [but] is satisfied by something less than acts or omissions for the very purpose of causing harm or with knowledge that harm will result.” Id. at 835. To exhibit deliberate

indifference, a prison official “must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference.” Id. at 837. Prison officials who act with deliberate indifference “to the threat of serious harm or injury” by one prisoner against another are subject to liability under the Eighth

Amendment through § 1983. Berg v. Kincheloe, 794 F.2d 457, 459 (9th Cir. 1986). “Having incarcerated persons with demonstrated proclivities for antisocial criminal, and often violent, conduct, having stripped them of virtually every means of self-protection and foreclosed their access to outside aid, the government and its officials are not free to let the state of nature take its course.” Farmer, 511 U.S. at 833 (internal quotation marks, citation,

and alterations omitted). Although even an obvious danger does not result in liability if the official is not subjectively aware of it, a prison official cannot “escape liability for deliberate indifference by showing that, while he was aware of an obvious, substantial risk to inmate safety, he did not know that the complainant was especially likely to be assaulted by the specific prisoner who eventually committed the assault.” Id. at 843.

3. Discussion of Federal Claims A. Defendants Idaho State Correctional Center, Idaho Department of Correction, and State of Idaho

The state of Idaho and branches of the state government, including the IDOC and the ISCC, are immune from suit in federal court. In Hans v. Louisiana, 134 U.S. 1

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Garcia v. Idaho State Correction Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-v-idaho-state-correction-center-idd-2020.