Kenneth Edward Tan v. Yuba County Jail, et al.

District Court, E.D. California·Decided February 12, 2026·No. 2:24-cv-00437·Unknown

Opinion

KENNETH EDWARD TAN, No. 2:24-cv-0437-EFB (PC) Plaintiff, v. ORDER AND RECOMMENDATIONS YUBA COUNTY JAIL, et al., Defendants. Plaintiff is a county jail inmate proceeding without counsel in an action brought under 42 U.S.C. § 1983. Plaintiff filed his complaint on January 31, 2024, and filed exhibits in support of his complaint on April 11, 2024. ECF Nos 1, 11. Upon screening, the court found a potentially cognizable conditions of confinement claim against defendants.1 ECF No. 14. Defendants (except the Doe Nurses) now move to dismiss the complaint for failure to state a claim because 1) it fails to identify which defendants were personally and individually involved in constitutional violation, and 2) it does not state a claim under the Fourteenth Amendment for deliberate indifference to plaintiff’s jail conditions. ECF No. 31. Plaintiff has filed his opposition (ECF No. 35), and defendants have replied (ECF No. 37).

1 Defendants Kandola, Little, Gillan, and Asouza are correctional sergeants, defendants Gomez, Houston, Marshall, Henry #1, Bronson, Babs, Samra, Chavez, Thomas, Cacho, and Singh are correctional officers, and the Doe Nurses #1-10 are sued their capacities as medical staff. ECF No. 1 at 10-13. Also before the court are: (1) plaintiff’s motion for default judgment (ECF No. 33); (2) plaintiff’s motion for limited discovery (ECF Nos. 53, 54); (3) plaintiff’s motion for leave to amend his complaint (ECF No. 38); (4) plaintiff’s motion for court-ordered production of discovery (ECF Nos. 41, 42); (5) plaintiff’s two motions concerning preservation of evidence (ECF No. 40; ECF No. 43); and (6) plaintiff’s motion to order use of registered return receipt mail (ECF No. 45). For the following reasons, the court will deny plaintiff’s motions regarding the conduct and timing of discovery. The remaining motions must be denied, and plaintiff must be allowed leave to file an amended complaint. I. Defendants’ Motion to Dismiss A. Plaintiff’s Allegations The complaint alleges that plaintiff was housed in unsanitary conditions in a cell in the Yuba County Jail’s F-Pod while quarantined with COVID-19 from September 18-29, 2023. ECF No. 1 at 3-20. According to these allegations, there was an open sewage leak that constantly pooled inside and outside the cell, defendants knew of the condition either because it was obvious to persons walking past the cell and/or because plaintiff complained, but defendants ignored his pleas to move. Id. at 3-5, 13, 15-18. B. Legal Standards 1. Federal Rule of Civil Procedure 12(b)(6) Standard A complaint may be dismissed for “failure to state a claim upon which relief may be granted.” Fed. R. Civ. P. 12(b)(6). To survive a motion to dismiss for failure to state a claim, a plaintiff must allege “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim has “facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 556). The plausibility standard is not akin to a “probability requirement,” but it requires more than a sheer possibility that a defendant has acted unlawfully. Iqbal, 556 U.S. at 678. Dismissal under Rule 12(b)(6) may be based on either: (1) lack of a cognizable legal theory, or (2) insufficient facts under a cognizable legal theory. Chubb Custom Ins. Co., 710 F.3d at 956. Dismissal also is appropriate if the complaint alleges a fact that necessarily defeats the claim. Franklin v. Murphy, 745 F.2d 1221, 1228-1229 (9th Cir. 1984). In resolving a Rule 12(b)(6) motion to dismiss, the court must construe the complaint in the light most favorable to the plaintiff and accept all well-pleaded factual allegations as true (and any reasonable inference supported by the facts). Broam v. Bogan, 320 F.3d 1023, 1028 (9th Cir. 2003). For purposes of dismissal under Rule 12(b)(6), the court generally considers only allegations contained in the pleadings, exhibits attached to the complaint, and matters properly subject to judicial notice, and construes all well-pleaded material factual allegations in the light most favorable to the nonmoving party. Chubb Custom Ins. Co. v. Space Sys./Loral, Inc., 710 F.3d 946, 956 (9th Cir. 2013); Akhtar v. Mesa, 698 F.3d 1202, 1212 (9th Cir. 2012) 2. Conditions of Confinement Standard To prevail on a clam under § 1983, a plaintiff must demonstrate: (1) the violation of a federal constitutional or statutory right; and (2) that the violation was committed by a person acting under color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). An individual defendant is not liable on a civil rights claim unless the facts establish the defendant's personal involvement in the constitutional deprivation or a causal connection between the defendant's wrongful conduct and the alleged constitutional deprivation. Hansen v. Black, 885 F.2d 642, 646 (9th Cir. 1989). Plaintiff and defendants appear to agree that plaintiff’s § 1983 conditions of confinement claim arises under the Fourteenth Amendment. ECF No. 1 at 4; ECF No. 31-1 at 4. The court therefore presumes that at the time of the events in question plaintiff was a pretrial detainee who had not already been convicted. Redman v. City of San Diego, 942 F.2d 1435, 1440 n.7 (9th Cir. 1991), abrogated on other grounds by Farmer v. Brennan, 511 U.S. 825 (1994) (“while the Eighth Amendment proscribes cruel and unusual punishment for convicted inmates, the due process clause of the Fourteenth Amendment proscribes any punishment of pretrial detainees”); see also Perez v. Cox, 788 F. App’x 438, 442 (9th Cir. 2019) (recognizing abrogation on other grounds). The elements of a Fourteenth Amendment deliberate indifference claim are: (1) The defendant made an intentional decision with respect to the conditions under which the plaintiff was confined; (2) Those conditions put the plaintiff at substantial risk of suffering serious harm; (3) The defendant did not take reasonable available measures to abate that risk, even though a reasonable officer in the circumstances would have appreciated the high degree of risk involved—making the consequences of the defendant's conduct obvious; and

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Kenneth Edward Tan v. Yuba County Jail, et al., (E.D. Cal. 2026).

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