Jeff Kile v. J. Doerer

CourtDistrict Court, E.D. California
DecidedOctober 7, 2025
Docket1:24-cv-01177
StatusUnknown

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

Bluebook
Jeff Kile v. J. Doerer, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 JEFF KILE, No. 1:24-cv-01177-KES-SAB (PC) 12 Plaintiff, FINDINGS AND RECOMMENDATION RECOMMENDING DISMISSAL OF ACTION 13 v. FOR FAILURE TO STATE A COGNIZABLE CLAIM FOR RELIEF 14 J. DOERER, (ECF No. 26) 15 Defendant.

16 17 Plaintiff is proceeding pro se and in forma pauperis in this civil rights action. 18 Plaintiff’s complaint in this action was filed on September 18, 2024. (ECF No. 1.) 19 On July 29, 2025, the Court screened the complaint, found that Plaintiff failed to state a 20 cognizable claim for relief, and granted Plaintiff thirty days to file an amended complaint. (ECF 21 No. 25.) 22 Plaintiff failed to file an amended complaint or otherwise respond to the July 29, 2025 23 order. Therefore, on September 8, 2025, the Court issued an order for Plaintiff to show cause 24 why the action should not be dismissed. (ECF No. 26.) Plaintiff has failed to respond to the 25 order to show cause and the time to do so has now passed. Thus, the operative complaint before 26 the Court is the initial complaint, which as explained below, fails to state a cognizable claim for 27 relief and dismissal of the action is warranted. 28 1 I. 2 SCREENING REQUIREMENT 3 The Court is required to screen complaints brought by prisoners seeking relief against a 4 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 5 Court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 6 “frivolous or malicious,” that “fail[] to state a claim on which relief may be granted,” or that 7 “seek[] monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 8 1915(e)(2)(B); see also 28 U.S.C. § 1915A(b). 9 A complaint must contain “a short and plain statement of the claim showing that the 10 pleader is entitled to relief. . . .” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not 11 required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere 12 conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell 13 Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Moreover, Plaintiff must demonstrate 14 that each defendant personally participated in the deprivation of Plaintiff’s rights. Jones v. 15 Williams, 297 F.3d 930, 934 (9th Cir. 2002). 16 Prisoners proceeding pro se in civil rights actions are entitled to have their pleadings 17 liberally construed and to have any doubt resolved in their favor. Wilhelm v. Rotman, 680 F.3d 18 1113, 1121 (9th Cir. 2012) (citations omitted). To survive screening, Plaintiff’s claims must be 19 facially plausible, which requires sufficient factual detail to allow the Court to reasonably infer 20 that each named defendant is liable for the misconduct alleged. Iqbal, 556 U.S. at 678-79; Moss 21 v. U.S. Secret Service, 572 F.3d 962, 969 (9th Cir. 2009). The “sheer possibility that a defendant 22 has acted unlawfully” is not sufficient, and “facts that are ‘merely consistent with’ a defendant’s 23 liability” falls short of satisfying the plausibility standard. Iqbal, 556 U.S. at 678; Moss, 572 F.3d 24 at 969. 25 II. 26 COMPLAINT ALLEGATIONS 27 The incidents at issue in this complaint took place at the United States Penitentiary in 28 Atwater (USP Atwater). 1 On or about August 9 to October 9, 2024, USP Atwater was placed on lockdown for 60 2 days requiring inmates to be confined to their cells for 24 hours a day. During this time, the Unit 3 Team (consisting of Plaintiff’s unit manager, case manager, and counselor) were responsible to 4 make administrative remedy forms (including Federal Tort Claims Act forms) available to 5 Plaintiff. Plaintiff had no way to approach the Unit Team members to request administrative 6 remedy forms. Plaintiff sent a copout via institutional mail to the Unit Team requesting informal 7 resolution of issues. 8 During the lockdown, Plaintiff was “cut off from the world” and denied: (1) access to 9 current events; (2) communication with anyone outside the facility; (3) access to the court; (4) 10 access to medical treatment; (5) access to his personal property; (6) access to cleaning supplies; 11 and (7) access to commissary. 12 Plaintiff attempts to bring the following claim: (1) denial of access to administrative 13 remedy forms; (2) denial of free speech and access to the courts in violation of the First 14 Amendment; (3) denial of medical care under the Eighth Amendment; (4) denial of property in 15 violation of the Fifth Amendment; (5) cruel and unusual punishment relating to the conditions of 16 confinement under the Eighth Amendment; and (6) illegal search and seizure under the Fourth 17 Amendment. 18 III. 19 DISCUSSION 20 A. Bivens 21 Not all constitutional cases against federal officers for damages may proceed as Bivens 22 claims. There is a two-part test to determine whether a Bivens action may proceed. Ziglar v. 23 Abbasi, 582 U.S. 138-139 (2017). To determine whether a Bivens claim is cognizable, a court 24 first “ask[s] whether the case presents ‘a new Bivens context’—i.e., is it ‘meaningful[ly]’ 25 different from the three cases in which the Court has implied a damages action.” Egbert v. Boule, 26 596 U.S. 482, 492 (2022) (quoting Ziglar v. Abbasi, 582 U.S. at 139). That is, the Court must 27 determine whether the claim presents a new context from the three cases the Supreme Court has 28 allowed to proceed under Bivens: Bivens v. Six Unknown Federal Narcotic Agents, 403 U.S. 388 1 (1971); Davis v. Passman, 442 U.S. 228 (1979); and Carlson v. Green, 446 U.S. 14 (1980). If the 2 answer is no, the claim may proceed. If the answer is yes, the court must apply a “special factors” 3 analysis to determine whether “special factors counsel hesitation” in expanding Bivens to the 4 action. Ziglar, 582 U.S. at 136. 5 In Egbert, the Supreme Court explained that the essential determination is “whether there 6 is any reason to think that Congress might be better equipped to create a damages remedy.” 142 7 S.Ct. at 1803. If any rational reason exists to defer to Congress to establish a remedy, courts 8 “may not recognize a Bivens remedy.” Id. Further, the existence of alternative remedial 9 structures within the BOP can be a “special factor” to hesitate in finding an available Bivens 10 remedy. 11 Turning to Plaintiff’s claims, the Supreme Court has never recognized a Bivens remedy 12 under the First Amendment and the Ninth Circuit has also refused to extend a Bivens remedy to a 13 claim under the First Amendment. Reichle v. Howards, 566 U.S. 658, 663 n.4 (2012) (citing 14 Iqbal, 556 U.S. at 675; Bush v. Lucas, 462 U.S. 367, 368 (1983)); Lee v. Matevousian, 2018 WL 15 5603593, at *3-4 (E.D. Cal. Oct. 26, 2018) (declining to infer Bivens remedy for First 16 Amendment retaliation and denial of access to courts claims). Since Ziglar v. Abbasi, the Ninth 17 Circuit has declined to extend the Bivens remedy to claims brought under the First Amendment. 18 See Schwarz v. Meinberg, 761 F.

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408 U.S. 564 (Supreme Court, 1972)
Davis v. Passman
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Bush v. Lucas
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Bell Atlantic Corp. v. Twombly
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Ashcroft v. Iqbal
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Wilhelm v. Rotman
680 F.3d 1113 (Ninth Circuit, 2012)
John Snow v. E.K. McDaniel
681 F.3d 978 (Ninth Circuit, 2012)
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Bluebook (online)
Jeff Kile v. J. Doerer, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jeff-kile-v-j-doerer-caed-2025.