Jose Angel Santos v. California Department of Corrections, et al.

CourtDistrict Court, E.D. California
DecidedDecember 3, 2025
Docket2:25-cv-01988
StatusUnknown

This text of Jose Angel Santos v. California Department of Corrections, et al. (Jose Angel Santos v. California Department of Corrections, et al.) 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
Jose Angel Santos v. California Department of Corrections, et al., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 JOSE ANGEL SANTOS, 2:25-cv-1988-CKD P 12 Plaintiff, 13 v. ORDER AND 14 CALIFORNIA DEPARTMENT OF FINDINGS AND RECOMMENDATIONS CORRECTIONS, et al., 15 Defendants. 16 17 Plaintiff Jose Santos, a state prisoner, seeks relief under 42 U.S.C. § 1983. Because 18 plaintiff proceeds without counsel, this case is referred to the undersigned by Local Rule 302. See 19 28 U.S.C. § 636(b)(1). Plaintiff’s complaint, request to proceed in forma pauperis, and motion for 20 injunctive relief are before the court. (ECF Nos. 1, 2, 3.) 21 I. In Forma Pauperis 22 Plaintiff’s declaration in support of the motion to proceed in forma pauperis makes the 23 showing required by 28 U.S.C. § 1915(a). The motion is granted. By separate order, plaintiff will 24 be assessed an initial partial filing fee in accordance with the provisions of 28 U.S.C. § 25 1915(b)(1). The order will direct the appropriate agency to collect the initial partial filing fee 26 from plaintiff’s trust account and forward it to the Clerk of the Court. Thereafter, plaintiff will be 27 obligated for monthly payments of twenty percent of the preceding month’s income credited to 28 plaintiff’s prison trust account. These payments will be forwarded by the appropriate agency to 1 the Clerk of the Court each time the amount in plaintiff’s account exceeds $10.00 until the filing 2 fee is paid in full. 28 U.S.C. § 1915(b)(2). 3 II. Screening Requirement 4 The court is required to screen complaints brought by prisoners seeking relief against a 5 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 6 court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 7 “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek 8 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1), (2). 9 III. Allegations in the Complaint 10 Plaintiff alleges he was compelled to sign an Assignment Card to participate in “DRP” 11 Group under duress and threat of disciplinary action by defendant John Doe #1. (ECF No. 1 at 5.) 12 As part of the course curriculum, participants in DRP Group are required to reveal in writing 13 personal information regarding their criminal history, case factors, victims, etc. (Id.) Defendant 14 McCoy is the AOD Counselor who ran the DRP Group and would insist that everyone participate 15 under threat of disciplinary action or dismissal as a “Program Failure.” (Id.) 16 Plaintiff does not believe he is required to take the course and asserts defendants have 17 refused to provide written proof of authorization to mandate his attendance. (ECF No. 1 at 6.) 18 Plaintiff asserts violations of his right to due process of law, Fifth Amendment right against self- 19 incrimination, Eighth Amendment right to be free of cruel and unusual punishment, and 20 California’s Tom Bane Act. (Id. at 5-6.) Plaintiff also brings a claim asserting deprivation of the 21 right to request public records under the Freedom of Information Act (“FOIA”). (Id. at 7.) 22 IV. Discussion 23 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two elements: (1) a right 24 secured by the Constitution or laws of the United States was violated and (2) the violation was 25 committed by a person or entity acting under the color of state law. See West v. Atkins, 487 U.S. 26 42, 48 (1988). Plaintiff’s allegations do not state a § 1983 claim for the following reasons. 27 First, the complaint does not plausibly allege a violation of plaintiff’s Fifth Amendment 28 right regarding self-incrimination. The Fifth Amendment privileges an individual not to answer 1 official questions put to him in any proceeding, civil or criminal, formal or informal, where the 2 answers might incriminate him in future criminal proceedings. Baxter v. Palmigiano, 425 U.S. 3 308, 316 (1976). Under the facts alleged in the complaint there is no suggestion that revealing 4 information about plaintiff’s criminal history, case factors, victims, etc., could incriminate him in 5 future criminal proceedings. 6 Second, the complaint does not plausibly allege a due process violation. “The 7 requirements of procedural due process apply only to the deprivation of interests encompassed by 8 the Fourteenth Amendment’s protection of liberty and property.” Board of Regents v. Roth, 408 9 U.S. 564, 569 (1972). In the prison context, procedural due process protections apply only where 10 the specific deprivation at issue constitutes “atypical and significant hardship on the inmate in 11 relation to the ordinary incidents of prison life.” Sandin v. Conner, 515 U.S. 472, 484 (1995). 12 Plaintiff’s alleged deprivation—being mandated to participate in DRP course— does not impose 13 an atypical and significant hardship on plaintiff relative to the basic conditions of life as a 14 prisoner. 15 Third, the complaint does not plausibly allege a violation of the Eighth Amendment’s 16 prohibition on cruel and unusual punishment. Prison officials have a duty to provide inmates with 17 humane conditions of confinement. Farmer v. Brennan, 511 U.S. 825, 832. (1994). To violate the 18 Eighth Amendment, “a prison official’s act or omission must result in the denial of the minimal 19 civilized measure of life’s necessities.” Farmer, 511 U.S. at 832, 834. A cognizable Eighth 20 Amendment claim requires facts showing: (1) the deprivation alleged is objectively sufficiently 21 serious; and (2) the prison official possessed a sufficiently culpable state of mind. Id. at 834. 22 Plaintiff’s allegations about being compelled to participate in DRP Group do not describe a 23 deprivation that is sufficiently serious to implicate the Eighth Amendment or a defendant who 24 acted with a sufficiently culpable state of mind to plaintiff’s health or safety to have acted in a 25 deliberately indifferent manner. 26 In addition, the complaint fails to state any claim under FOIA. FOIA requires federal 27 agencies to make certain information available to the public. See 5 U.S.C. § 552. Plaintiff’s 28 allegations do not describe information held by federal agencies. 1 Finally, plaintiff has not alleged compliance with California’s Government Claims Act 2 (“GCA”) which is required to state a Bane Act Claim. See Mohsin v. California Dep’t of Water 3 Res., 52 F. Supp. 3d 1006, 1017 (E.D. Cal. 2014) (dismissing state law claims for failure to allege 4 compliance with GCA). No state claim for money or damages may be brought against a public 5 entity unless those claims have been presented for review and rejected by a notice issued or a 6 failure to act. See Cal. Gov’t Code § 900 et seq. 7 V.

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Jose Angel Santos v. California Department of Corrections, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jose-angel-santos-v-california-department-of-corrections-et-al-caed-2025.