Jones v. Pierce County Jail

CourtDistrict Court, W.D. Washington
DecidedJanuary 24, 2020
Docket3:19-cv-06241
StatusUnknown

This text of Jones v. Pierce County Jail (Jones v. Pierce County Jail) 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
Jones v. Pierce County Jail, (W.D. Wash. 2020).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 TERRELL E. JONES, CASE NO. 3:19-cv-06241-BHS-JRC 11 Plaintiff, ORDER TO SHOW CAUSE OR 12 v. AMEND COMPLAINT 13 PIERCE COUNTY JAIL, et al., 14 Defendants. 15 16 This matter is before the Court on plaintiff’s complaint under 42 U.S.C. § 1983, which 17 the District Court has referred to the undersigned. See Dkt. 2. Plaintiff, who is a pretrial 18 detainee proceeding in forma pauperis and pro se, seeks damages from defendants Pierce County 19 Jail and A. Mastrada for alleged unconstitutional conditions of confinement—namely filthy 20 recreation yard conditions that plaintiff states caused him to become ill. 21 Plaintiff’s claims against Pierce County Jail and defendant Mastrada in his official 22 capacity fail because plaintiff does not bring them against the proper defendant (Pierce County) 23 and does not allege a municipal custom, policy, or practice that caused the alleged constitutional 24 1 violation. However, the Court will offer plaintiff an opportunity to amend these claims before 2 service, if he wishes to proceed against the County. Failure to show cause or amend the 3 complaint will result in the undersigned recommending dismissal of all claims except claims 4 brought against defendant Mastrada in his individual capacity for damages. If plaintiff takes no

5 action in response to this Order by February 28, 2020, then the undersigned will direct service 6 of the complaint on only defendant Mastrada. 7 8 BACKGROUND 9 Plaintiff alleges violations of the Eighth Amendment related to conditions of his pretrial 10 confinement at Pierce County Jail. See Dkt. 5, at 4. Specifically, plaintiff alleges that on 11 September 5, 2019, he was taken to the jail yard, where there was “visibly an inexcusable 12 amount of bird droppings and feathers littered around the yard area.” Dkt. 5, at 4–5. Defendant 13 Mastrada—who plaintiff alleges “had the authority to close the rec yard”—was alerted and “took 14 notice of the area[,] said he’d work on it[,] and left.” Dkt. 5, at 5. Plaintiff had to remain in the

15 yard in the meantime, which he alleges caused him to become ill, to begin vomiting, and to 16 ultimately be left bedridden with physical symptoms for a week. See Dkt. 5, at 5. He requests 17 monetary damages from defendant Mastrada for deliberate indifference (for not closing the 18 recreation yard immediately and allowing individuals to remain in the yard after learning of the 19 unsanitary conditions) and from defendant Pierce County Jail. See Dkt. 5, at 5, 9. 20 /// 21 /// 22 /// 23 ///

24 1 DISCUSSION 2 I. Screening Standards 3 Because plaintiff brings claims against a government entity and a government employee, 4 the Court must review his complaint and dismiss any portion of the complaint that fails to state a

5 claim upon which relief can be granted. See 28 U.S.C. § 1915A. However, because plaintiff is 6 pro se, the Court will offer him an opportunity to amend his complaint unless it appears that any 7 amendment would be futile. See Flowers v. First Hawaiian Bank, 295 F.3d 966, 976 (9th Cir. 8 2002). Here, plaintiff’s complaint suffers from deficiencies that will result in the undersigned 9 recommending dismissal of certain claims unless plaintiff corrects those claims in an amended 10 complaint. 11 II. Claims Against Defendant Mastrada in Individual Capacity 12 The Court interprets plaintiff’s claims as claims under the Fourteenth Amendment, since 13 plaintiff alleges that he was a pretrial detainee at the time. See Castro v. Cty. of L.A., 833 F.3d 14 1060, 1067–68 (9th Cir. 2016) (pretrial detainees’ claims considered under the Fourteenth

15 Amendment, not the Eighth Amendment). 16 In order to state a claim for relief under 42 U.S.C. § 1983, a plaintiff must show that (1) 17 he suffered a violation of rights protected by the Constitution or created by federal statute and (2) 18 the violation was proximately caused by a person acting under color of state law. See Crumpton 19 v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). To prevail on a conditions of confinement claim 20 under the Fourteenth Amendment, a pretrial detainee must show that the conditions under which 21 the detainee was confined put him at “substantial risk of suffering serious harm.” See Castro, 22 833 F.3d at 1071. Moreover, such a claim requires a showing of “objective indifference, not 23 subjective indifference” by the prison official. See Gordan v. Cty. of Orange, 888 F.3d 1118,

24 1 1120 (9th Cir. 2018). Objective indifference is “more than negligence but less than subjective 2 intent—something akin to reckless disregard.” Castro, 888 F.3d at 1071. 3 Solely for the purposes of § 1915A screening, the Court finds that plaintiff has 4 adequately stated a claim that defendant Mastrada in his individual capacity violated the

5 Fourteenth Amendment. Plaintiff alleges that Mastrada disregarded a substantial risk of serious 6 harm posed by not immediately closing the recreation yard, which caused plaintiff to become 7 physically ill. However, the Court cautions plaintiff that even if he has adequately alleged this 8 claim for screening purposes, that does not mean that the claim will necessarily survive any 9 motion to dismiss. Further, plaintiff’s remaining claims are deficient in the respects discussed in 10 the remainder of this Order. 11 III. Claims Against Pierce County Jail and Against Defendant Mastrada in Official 12 Capacity 13 Plaintiff requests damages for the allegedly unconstitutional yard conditions from 14 defendant Pierce County Jail. However, the proper defendant for such a claim is Pierce

15 County—not the jail—since Pierce County is the municipal entity at issue. See, e.g., Vance v. 16 Cty. of Santa Clara, 928 F. Supp. 993, 996 (N.D. Cal. 1996). 17 Moreover, even if plaintiff amends his pleading to list Pierce County as a defendant, his 18 claim is inadequate because local governments are not liable simply on the basis that their 19 employees committed misconduct. See Connick v. Thompson, 563 U.S. 51, 60 (2011). A claim 20 against a municipality requires a showing that the constitutional violation was committed 21 “pursuant to a formal governmental policy or a ‘longstanding practice or custom which 22 constitutes the standard operating procedure of the local governmental entity.’” Gillette v. 23 Delmore, 979 F.2d 1342, 1346 (9th Cir. 1992) (citation omitted). “Official municipal policy

24 1 includes the decisions of a government’s lawmakers, the acts of its policymaking officials, and 2 practices so persistent and widespread as to practically have the force of law.” Connick, 563 3 U.S. at 61. A plaintiff must show that the policy, practice, or custom caused the constitutional 4 deprivation. See Trevino v. Gates, 99 F.3d 911, 918 (9th Cir. 1996). And like all allegations,

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Jones v. Pierce County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-pierce-county-jail-wawd-2020.