Goodlett v. Delgado

CourtDistrict Court, S.D. California
DecidedNovember 15, 2021
Docket3:19-cv-01922
StatusUnknown

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

Bluebook
Goodlett v. Delgado, (S.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9 Randall GOODLETT, Case No.: 19-cv-1922-AJB-AGS 10 Plaintiff, REPORT AND RECOMMENDATION TO GRANT DEFENDANT 11 v. DELGADO’S MOTION TO DISMISS 12 Ramiro DELGADO, et al., (ECF 27) 13 Defendants. 14 15 Earlier in this case, the Court dismissed three of plaintiff’s claims. But one defendant 16 had not been served at the time. Now that he has, he requests dismissal of those same claims 17 on the same bases, which plaintiff does not oppose. So, for the same reasons as previously 18 given, this Court recommends defendant Delgado’s motion to dismiss be granted. 19 BACKGROUND 20 While incarcerated at R.J. Donovan Correctional Facility, plaintiff Randall Goodlett 21 alleges that a prison guard knocked him unconscious without provocation and that other 22 officers failed to intervene or report the misconduct. (ECF 1, at 3-5.) After transferring to 23 a new prison, Goodlett filed this 42 U.S.C. § 1983 action against those guards. (Id. at 1.) 24 In January 2020, all four of the defendants moved to dismiss three portions of Goodlett’s 25 complaint: (1) the Fourteenth Amendment substantive-due-process claim; (2) the request 26 for money damages against defendants in their official capacities; and (3) the injunctive 27 relief claim. (ECF 9.) That motion to dismiss was granted on September 11, 2020, based 28 on this Court’s recommendation. (ECF 13; ECF 12.) But one defendant—Delgado—had 1 not yet been served at the time the January 2020 motion to dismiss was filed. (ECF 27, 2 at 3.) 3 Delgado, now served, filed the present motion out “of an abundance of caution and 4 to facilitate a clear and procedurally appropriate record.” (Id.) This motion seeks to dismiss 5 the same three claims against Delgado that the September 11, 2020 Order dismissed 6 against the other defendants. (Id. at 2.) Delgado seeks the partial dismissal on the “precise 7 same legal grounds.”1 (Id. at 6.) Goodlett was served a copy of this motion on June 1, 2021, 8 but did not respond. Delgado filed a notice of a failure to oppose on July 15, 2021, and the 9 motion to dismiss remains unopposed by Goodlett. (ECF 30.) 10 DISCUSSION 11 This court may dismiss a case for “failure to state a claim upon which relief can be 12 granted.” See Fed. R. Civ. P. 12(b)(6). When deciding a motion to dismiss, the Court’s 13 “inquiry is limited to the allegations in the complaint, which are accepted as true and 14 construed in the light most favorable to the plaintiff.” Lazy Y Ranch LTD v. Behrens, 15 546 F.3d 580, 588 (9th Cir. 2008). If a plaintiff proceeds without an attorney, like Goodlett 16 here, the Court has an obligation to “construe the pleadings liberally” and afford plaintiff 17 the “benefit of any doubt.” Martinez v. Barr, 941 F.3d 907, 916 (9th Cir. 2019). 18 19 20 21 1 Ordinarily, the Court should observe district court determinations on pretrial 22 motions as “the law of the case.” United States v. Phillips, 367 F.3d 846, 856 23 (9th Cir. 2004) (“Issues that a district court determines during pretrial motions become law of the case.”). In this case, the district court’s prior ruling on identical legal arguments 24 would apply to Delgado as well, as he is situated identically to the guards dismissed in 25 September 2020. But the “law of the case doctrine” is only “a guide to discretion.” United States v. Lewis, 611 F.3d 1172, 1179 (9th Cir. 2010) (“Law of the case is a discretionary 26 doctrine: It ‘merely expresses the practice of courts generally to refuse to reopen what has 27 been decided, not a limit to their power.’” (citing Messinger v. Anderson, 225 U.S. 436, 444)). Given Goodlett’s appearance without an attorney, the Court exercises its discretion 28 1 A. Fourteenth Amendment Due Process Claim 2 Delgado moves to dismiss Goodlett’s Fourteenth Amendment due-process claim, 3 arguing that it is duplicative of his allegations of “excessive force and failure to intervene 4 under the Eighth Amendment.”2 (ECF 27, at 8.) When a specific constitutional Amendment 5 “provides an explicit textual source of constitutional protection against a particular sort of 6 government behavior, that Amendment, not the more generalized notion of ‘substantive 7 due process,’ must be the guide for analyzing these claims.” Albright v. Oliver, 8 510 U.S. 266, 273 (1994) (plurality) (quotation marks omitted). Thus, any “protection that 9 ‘substantive due process’ affords convicted prisoners against excessive force is . . . at best 10 redundant of that provided by the Eighth Amendment.” Graham v. Connor, 11 490 U.S. 386, 395 n.10 (1986). 12 Goodlett alleges that Delgado used excessive force against him “by slamming [him] 13 to the ground, knocking [him] unconscious.” (ECF 1, at 4.) Like the failure-to-intervene 14 and improper-transportation allegations levied against the other three defendants (id.), such 15 a claim falls squarely within the Eighth Amendment’s explicit protections: that 16 Amendment “is specifically concerned with the unnecessary and wanton infliction of pain 17 in penal institutions.” Whitley v. Albers, 475 U.S. 312, 327 (1986). As a result, Goodlett’s 18 due-process “claim is preempted by the Eighth Amendment and should not be analyzed as 19 a substantive due process claim under the Fourteenth Amendment.” See Easter v. CDC, 20 694 F. Supp. 2d 1177, 1187 (S.D. Cal. 2010). 21 22 23 24 2 This Court interprets Goodlett’s cruel-and-unusual-punishment cause of action 25 (Count 3) as a claim under the Eighth Amendment as incorporated through the Fourteenth Amendment. See Robinson v. California, 370 U.S. 660, 667 (1962) (applying “cruel and 26 unusual punishment” protection to state action through Fourteenth Amendment). 27 Defendants identify Count 2 (“Civil misconduct right to due process”) as the offending Fourteenth Amendment due-process claim. (See ECF 1, at 4; ECF 27, at 4.) The Court’s 28 1 B. Claim for Damages in Defendant’s Official Capacity 2 Delgado also moves to dismiss Goodlett’s claims for damages against him in his 3 official capacity. “The Eleventh Amendment bars suits for money damages in federal court 4 against a state, its agencies, and state officials acting in their official capacities,” unless the 5 state consents. See Aholelei v. Dep’t of Pub. Safety, 488 F.3d 1144, 1147 (9th Cir. 2007). 6 Although Congress may revoke this state immunity, “Congress, in passing § 1983, had no 7 intention to disturb the States’ Eleventh Amendment immunity.” Will v. Mich. Dep’t of 8 State Police, 491 U.S. 58, 66 (1989). Thus, just like the guards dismissed in the September 9 2020 Order, Delgado “acting in [his] official capacit[y] cannot be sued for damages under 10 Section 1983.” See Goldstein v. City of Long Beach, 715 F.3d 750, 753 (9th Cir. 2013). 11 C.

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Related

Messenger v. Anderson
225 U.S. 436 (Supreme Court, 1912)
Robinson v. California
370 U.S. 660 (Supreme Court, 1962)
Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
United States v. Lewis
611 F.3d 1172 (Ninth Circuit, 2010)
Armstrong v. Schwarzenegger
622 F.3d 1058 (Ninth Circuit, 2010)
Thomas Goldstein v. City of Long Beach
715 F.3d 750 (Ninth Circuit, 2013)
Lazy Y Ranch Ltd. v. Behrens
546 F.3d 580 (Ninth Circuit, 2008)
Easter v. CDC
694 F. Supp. 2d 1177 (S.D. California, 2010)

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Goodlett v. Delgado, Counsel Stack Legal Research, https://law.counselstack.com/opinion/goodlett-v-delgado-casd-2021.