Hash v. Giacomazzi

CourtDistrict Court, N.D. California
DecidedMarch 23, 2021
Docket5:20-cv-01116
StatusUnknown

This text of Hash v. Giacomazzi (Hash v. Giacomazzi) 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
Hash v. Giacomazzi, (N.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 LAWRENCE G. HASH, 11 Case No. 20-01116 EJD (PR) Plaintiff, 12 ORDER OF PARTIAL DISMISSAL AND OF SERVICE; DIRECTING v. 13 DEFENDANTS TO FILE

DISPOSITIVE MOTION OR

14 NOTICE REGARDING SUCH M. GIACOMAZZI, et al., MOTION; INSTRUCTIONS TO 15 CLERK Defendants.

18 Plaintiff, a state prisoner, filed the instant pro se civil rights action pursuant to 42 19 U.S.C. § 1983 against numerous prison staff at San Quentin State Prison (“SQSP”) and 20 other individuals. Dkt. No. 1. After an initial screening, the Court dismissed the 21 complaint with leave to amend for Plaintiff to attempt to correct deficiencies with respect 22 to some of the claims and to file other claims as a separate habeas action. Dkt. No. 11. 23 Plaintiff filed an amended complaint. Dkt. Nos. 15, 15-1. 24

25 DISCUSSION 26 A. Standard of Review 27 A federal court must conduct a preliminary screening in any case in which a 1 prisoner seeks redress from a governmental entity or officer or employee of a 2 governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any 3 cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim 4 upon which relief may be granted or seek monetary relief from a defendant who is immune 5 from such relief. See id. § 1915A(b)(1),(2). Pro se pleadings must, however, be liberally 6 construed. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 7 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 8 elements: (1) that a right secured by the Constitution or laws of the United States was 9 violated, and (2) that the alleged violation was committed by a person acting under the 10 color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). 11 B. Plaintiff’s Claims 12 Plaintiff’s amended complaint is 124 pages long and names 109 Defendants. Dkt. 13 Nos. 15, 15-1. The amended complaint is accompanied by 175 pages of exhibits. Dkt 14 Nos. 15-2, 15-3.1 Plaintiff sets forth 4 claims. 15 1. Claims 1, 2, and 4 - Disciplinary Proceedings 16 Under claim 1, Plaintiff claims that he received inadequate notice in connection 17 with five Rules Violation Reports (“RVR”) that were issued by Defendant M. Giacomazzi 18 in February 2016, involving allegations that Plaintiff was the author of threatening notes 19 against staff members and their families. Dkt. No. 15 at 12. He claims his right to due 20 process was violated because the RVRs did not indicate the date, time or place where the 21 alleged misbehavior took place. Id. Plaintiff seeks declaratory relief and damages. Id. at 22 21-23. Under claim 2, Plaintiff also claims he was denied his right to procedural due 23 process based on the use of unreliable confidential and non-confidential information. Dkt. 24 No. 15-1 at 24, 27. Plaintiff alleges that he lost time credits as a result of the disciplinary 25 proceedings that found him guilty of the charges. Id. at 26. Under claim 4, Plaintiff 26 1 challenges another RVR for “possession of a deadly weapon” issued by Defendant 2 Giacomazzi on March 5, 2016, based on procedural due process violations. Id. at 54, 56, 3 58. The Court notes that in the original complaint, Plaintiff alleged that the guilty finding 4 for this RVR also resulted in the loss of time credits. Dkt. No. 1 at 91-92; Dkt. No. 1-1 at 5 175. Plaintiff seeks declaratory relief and damages. Dkt. No. 15-1 at 70-72. 6 In the initial screening order of the original complaint, the Court noted that under 7 claims 1, 2, and 4, Plaintiff was alleging due process violations in connection with 8 disciplinary proceedings that resulted in the revocation of good time credits. Dkt. No. 11 9 at 2-3. Plaintiff was advised that a challenge to a disciplinary finding that resulted in 10 assessment of time credits must be brought in habeas if reinstatement of the time credits 11 would “necessarily spell speedier release.” Id. at 3, citing Skinner v. Switzer, 562 U.S. 12 521, 525 (2011). Accordingly, the Court advised Plaintiff that the claims challenging the 13 RVRs should be brought as a petition for a writ of habeas corpus rather than a § 1983 14 action. Id. Lastly, Plaintiff was also advised that he may only pursue a claim for damages 15 in connection with the unlawful deprivation of time credits if he prevails on the habeas 16 action challenging the revocation of those credits. Id. at 4, citing Heck v. Humphrey, 512 17 U.S. 477, 486-487 (1994). The Court therefore dismissed the claims challenging the 18 RVRs that resulted in the loss of time credits without prejudice to filing as a separate 19 habeas action under 28 U.S.C. § 2254. Id. at 7. 20 In the amended complaint, Plaintiff is again raising the same due process claims 21 challenging the same RVRs as in the original complaint, which were dismissed by the 22 Court in its screening order. Dkt. No. 11 at 7. Accordingly, claims 1, 2, and 4 in the 23 amended complaint are again DISMISSED without prejudice to Plaintiff pursuing in 24 separate habeas actions. 25 2. Claim 3 - Retaliation 26 Under claim 3, Plaintiff claims prison staff took adverse action against him for 1 at 32, 47-50. Specifically, Plaintiff claims that on February 4, 2016, Defendants M. 2 Giacomazzi, P. G. Hannah, C. Bass, and C. Fry searched his cell based on Plaintiff filing 3 inmate appeals, staff complaints, and lawsuits against law enforcement officers. Id. at 37. 4 Plaintiff claims Defendants threatened to put him “in the hole” and transferred to another 5 prison. Id. at 38, 40. Plaintiff claims that later that same day, Defendants Sgt. D. Petrovic, 6 Lt. Daryl Dorsey, and Giacomazzi threatened to and did move him to the Adjustment 7 Center (“AC”), where they housed death row inmates for disciplinary matters. Id. at 41. 8 Plaintiff seeks declaratory relief, damages, and for the challenged RVRs (as described in 9 the above claims) be expunged and removed from his file. Id. at 51-53. Liberally 10 construed, Plaintiff’s allegations are sufficient to state a retaliation claim against 11 Defendants Giacomazzi, Hannah, Bass, Fry, Petrovic, and Dorsey. See Rhodes v. 12 Robinson, 408 F.3d 559, 567-68 (9th Cir. 2005). The Court also takes supplemental 13 jurisdiction over Plaintiff’s assertion of state law claims. Dkt. No. 15-1 at 32. However, 14 Plaintiff’s request for expungement and removal of the challenged RVRs must be made in 15 the habeas actions challenging the RVRs as discussed above. Accordingly, that portion of 16 his request for relief is DISMISSED. 17 3. Excessive Force 18 Plaintiff claims that during the cell search on February 4, 2016, “Defendants 19 Hannah and Giacomazzi used excessive force” on him while being handcuffed. Dkt. No. 20 15-1 at 37. Plaintiff provides no other description of their actions or why the force they 21 allegedly applied was excessive. Id. The Court notes that in the original complaint, 22 Plaintiff alleged that only Defendant Hannah intentionally handcuffed him too tightly in 23 “retaliation for being the author of the threatening notes.” Dkt. No. 11 at 6. Although the 24 Court found no basis for a retaliation claim, Plaintiff was granted leave to amend to 25 include a claim for excessive force “that is supported by sufficient factual allegations.” Id.

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Hash v. Giacomazzi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hash-v-giacomazzi-cand-2021.