Hall v. Pierce County

CourtDistrict Court, W.D. Washington
DecidedOctober 6, 2025
Docket3:25-cv-05747
StatusUnknown

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

Bluebook
Hall v. Pierce County, (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 JUNAID RAMSEY HALL, CASE NO. 3:25-cv-05747-RAJ-GJL 11 Plaintiff, v. ORDER GRANTING MOTION TO 12 AMEND AND DIRECTING PIERCE COUNTY, et al., PLAINTIFF TO FILE A SECOND 13 AMENDED COMPLAINT Defendant.

15 The District Court has referred this 42 U.S.C. § 1983 action to United States Magistrate 16 Judge Grady J. Leupold. Plaintiff Junaid Ramsey Hall is an inmate proceeding pro se and in 17 forma pauperis. Dkts. 7, 8. Prior to the Court screening Plaintiff’s Complaint, he filed a Motion 18 to Amend (Dkt. 12) and a proposed First Amended Complaint (“FAC”) (Dkt. 12-1).1 19 Having reviewed and screened Plaintiff’s FAC under 28 U.S.C. § 1915A, the Court 20 declines to serve the FAC. However, the Court GRANTS Plaintiff’s Motion to Amend (Dkt. 12) 21 and provides Plaintiff leave to file an amended pleading on or before November 6, 2025. 22 23 1 Plaintiff’s FAC acts as a complete substitute for his original Complaint and will be considered as the operative 24 complaint in this case. 1 I. BACKGROUND 2 Plaintiff, currently a pretrial detainee at Pierce County Jail (“PCJ”), initiated this civil 3 rights action alleging violation of his Fourteenth Amendment rights while a trustee worker at that 4 facility. In his sole claim for relief, Plaintiff alleges Defendant Torres improperly denied him rest

5 breaks, meals, and access to his prescription medications during his PM Laundry work shifts. 6 Plaintiff claims these deprivations caused him to suffer depression, anxiety, and to feel nauseous, 7 dizzy, faint, and weak. 8 Plaintiff asserts Defendant Torres’ supervisors, Defendants Braswell and Lincoln, knew 9 of the violation of Plaintiff’s rights but failed to remedy the situation. Plaintiff further alleges 10 Defendant Pierce County failed to properly train PCJ staff to avoid the alleged violation of 11 Plaintiff’s Fourteenth Amendment Rights. Plaintiff’s FAC seeks $100,000 in compensatory 12 damages, $10,000,000 in punitive damages, and injunctive relief requiring Defendant Pierce 13 County to provide additional training for PCJ staff regarding the necessity of meal and rest 14 breaks for trustee workers.

15 II. SCREENING STANDARD 16 Under the Prison Litigation Reform Act of 1995, the Court is required to screen 17 complaints brought by prisoners seeking relief against a governmental entity or officer or 18 employee of a governmental entity. 28 U.S.C. § 1915A(a). The Court must “dismiss the 19 complaint, or any portion of the complaint, if the complaint: (1) is frivolous, malicious, or fails to 20 state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant 21 who is immune from such relief.” Id. at (b); 28 U.S.C. § 1915(e)(2); see Barren v. Harrington, 22 152 F.3d 1193 (9th Cir. 1998). 23

24 1 To state a claim for relief under 42 U.S.C. § 1983, a plaintiff must show: (1) he suffered a 2 violation of rights protected by the Constitution or created by federal statute, and (2) the 3 violation was proximately caused by a person acting under color of state law. See Crumpton v. 4 Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). The first step in a § 1983 claim is therefore to

5 identify the specific constitutional right allegedly infringed. Albright v. Oliver, 510 U.S. 266, 271 6 (1994). 7 To satisfy the second prong, a plaintiff must allege facts showing how individually 8 named defendants caused, or personally participated in causing, the harm alleged in the 9 complaint. See Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988); Arnold v. IBM, 637 F.2d 10 1350, 1355 (9th Cir. 1981). A person subjects another to a deprivation of a constitutional right 11 when committing an affirmative act, participating in another’s affirmative act, or omitting to 12 perform an act which is legally required. Johnson v. Duffy, 588 F.2d 740, 743 (9th Cir. 1978). 13 Sweeping conclusory allegations against an official are insufficient to state a claim for relief. 14 Leer, 844 F.2d at 633. Further, a § 1983 suit cannot be based on vicarious liability alone, but

15 must allege the defendant’s own conduct violated the plaintiff’s civil rights. City of Canton v. 16 Harris, 489 U.S. 378, 385–90 (1989). 17 III. DISCUSSION 18 Upon review, the Court concludes the Plaintiff’s proposed FAC fails to state a claim 19 upon which relief can be granted. The Court notes the deficiencies set forth below. 20 A. Failure to State a § 1983 Claim 21 “It is undisputed that the treatment a prisoner receives in prison and the conditions under 22 which he is confined are subject to scrutiny under the Eighth Amendment.” Helling v. McKinney, 23 509 U.S. 25, 31 (1993); see also Farmer v. Brennan, 511 U.S. 825, 832 (1994). Challenges

24 1 brought by pretrial detainees relating to the conditions of their confinement are properly 2 analyzed under the Fourteenth Amendment’s Due Process Clause. Castro v. County of Los 3 Angeles, 833 F.3d 1060, 1067-68 (9th Cir. 2016). 4 “Pretrial detainees are entitled to ‘adequate food, clothing, shelter, sanitation, medical

5 care, and personal safety.’” Alvarez-Machain v. United States, 107 F.3d 696, 701 (9th Cir. 1996) 6 (quoting Hoptowit v. Ray, 682 F.2d 1237, 1246 (9th Cir. 1982)). To state a claim of 7 unconstitutional conditions of confinement against an individual defendant, a pretrial detainee 8 must allege facts that show: 9 (i) the defendant made an intentional decision with respect to the conditions under which the plaintiff was confined; (ii) those conditions put the plaintiff at substantial 10 risk of suffering serious harm; (iii) the defendant did not take reasonable available measures to abate that risk, even though a reasonable official in the circumstances 11 would have appreciated the high degree of risk involved—making the consequences of the defendant's conduct obvious; and (iv) by not taking such 12 measures, the defendant caused the plaintiff’s injuries.

13 Gordon v. County of Orange, 888 F.3d 1118, 1125 (9th Cir. 2018) (citation and quotation 14 omitted). To determine whether the conditions and conduct rise to the level of a constitutional 15 violation, one must conduct an objective assessment that turns on the facts and circumstances of 16 each particular case. Id.

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Hall v. Pierce County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-v-pierce-county-wawd-2025.