Lance Williams v. A. Rocha, et al.

District Court, E.D. California·Decided March 23, 2026·No. 1:24-cv-01506·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 LANCE WILLIAMS, Case No.: 1:24-cv-001506-CDB 12 Plaintiff, FINDINGS AND RECOMMENDATIONS TO DISMISS CERTAIN CLAIMS AND THE 13 v. DOE DEFENDANT FOLLOWING SCREENING OF PLAINTIFF’S FIRST 14 A. ROCHA, et al., AMENDED COMPLAINT

15 Defendants. 14-DAY OBJECTION PERIOD

16 Clerk of the Court to Assign District Judge

17 Plaintiff Lance Williams is proceeding pro se and in forma pauperis in this civil rights 18 action pursuant to 42 U.S.C. section 1983. 19 I. INTRODUCTION 20 On February 18, 2026, the Court issued its First Screening Order. (Doc. 18.) The Court 21 determined that Plaintiff stated plausible Eighth Amendment excessive force, failure to protect, 22 and deliberate indifference to serious medical needs against Defendants Rocha and Florez in 23 Claim I but failed to allege any other plausible claim against any other named defendant in Claim 24 II or Claim III. (Id. at 4-15.) Plaintiff was directed to do one of the following within 21 days: (1) 25 notify the Court in writing that he did not wish to file a first amended complaint and was willing 26 to proceed only on the Eighth Amendment excessive force claims against Defendants Rocha and 27 Florez (Claim I); Eighth Amendment failure to protect claims against Defendants Rocha and 1 Florez (Claim I); and Eighth Amendment deliberate indifference to serious medical needs claims 2 against Defendants Rocha and Florez (Claim I) with the remaining claims against any defendant 3 to be dismissed; or (2) file a first amended complaint curing the deficiencies identified by the 4 Court; or (3) file a notice of voluntary dismissal. (Id. at 17.) 5 On March 10, 2026, Plaintiff filed a document titled “Notice of Filing of Amended 6 Complaint and Clarification of Courts Screening and Request for Extension.” (Doc. 19.) 7 On March 11, 2026, Plaintiff filed a first amended complaint. (Doc. 20.) That same date, 8 the Court granted Plaintiff a 30-day extension of time within which to file a first amended 9 complaint and addressed his request for clarification. (See Doc. 21.) 10 Given Plaintiff’s filing of March 11, the Court presumes Plaintiff did not need the 11 requested extension of time and will screen the first amended complaint. 12 II. SCREENING REQUIREMENT 13 The Court is required to screen complaints brought by prisoners seeking relief against a 14 governmental entity or an officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). 15 The Court must dismiss a complaint or portion thereof if the complaint is frivolous or malicious, 16 fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant 17 who is immune from such relief. 28 U.S.C. § 1915A(b). The Court should dismiss a complaint if 18 it lacks a cognizable legal theory or fails to allege sufficient facts to support a cognizable legal 19 theory. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). 20 III. PLEADING REQUIREMENTS 21 A. Federal Rule of Civil Procedure 8(a) 22 “Rule 8(a)’s simplified pleading standard applies to all civil actions, with limited 23 exceptions.” Swierkiewicz v. Sorema N.A., 534 U.S. 506, 513 (2002). A complaint must contain 24 “a short and plain statement of the claims showing that the pleader is entitled to relief.” Fed. R. 25 Civ. P. 8(a)(2). “Such a statement must simply give the defendant fair notice of what the 26 plaintiff’s claim is and the grounds upon which it rests.” Swierkiewicz, 534 U.S. at 512 (internal 27 quotation marks & citation omitted). 1 cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 2 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Plaintiff must 3 set forth “sufficient factual matter, accepted as true, to ‘state a claim that is plausible on its face.’” 4 Id. (quoting Twombly, 550 U.S. at 570). Factual allegations are accepted as true, but legal 5 conclusions are not. Id. (citing Twombly, 550 U.S. at 555). 6 The Court construes pleadings of pro se prisoners liberally and affords them the benefit of 7 any doubt. Hebbe v. Pliler, 627 F.3d 338, 342 (9th Cir. 2010) (citation omitted). However, “the 8 liberal pleading standard . . . applies only to a plaintiff’s factual allegations,” not his legal 9 theories. Neitzke v. Williams, 490 U.S. 319, 330 n.9 (1989). Furthermore, “a liberal interpretation 10 of a civil rights complaint may not supply essential elements of the claim that were not initially 11 pled,” Bruns v. Nat’l Credit Union Admin., 122 F.3d 1251, 1257 (9th Cir. 1997) (internal 12 quotation marks & citation omitted), and courts “are not required to indulge unwarranted 13 inferences.” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation 14 marks & citation omitted). The “sheer possibility that a defendant has acted unlawfully” is not 15 sufficient to state a cognizable claim, and “facts that are merely consistent with a defendant’s 16 liability” fall short. Iqbal, 556 U.S. at 678 (internal quotation marks & citation omitted). 17 B. Linkage and Causation 18 Section 1983 provides a cause of action for the violation of constitutional or other federal 19 rights by persons acting under color of state law. See 42 U.S.C. § 1983. To state a claim under 20 section 1983, a “plaintiff must allege facts, not simply conclusions, that show that an individual 21 was personally involved in the deprivation of his civil rights.” Barren v. Harrington, 152 F.3d 22 1193, 1194 (9th Cir. 1998); see Iqbal, 556 U.S. at 676 (“Because vicarious liability is 23 inapplicable to Bivens and § 1983 suits, a plaintiff must plead that each Government-official 24 defendant, through the official’s own individual actions, has violated the Constitution”); Leer v. 25 Murphy, 844 F.2d 628, 633 (9th Cir. 1988) (“The inquiry into causation must be individualized 26 and focus on the duties and responsibilities of each individual defendant whose acts or omissions 27 are alleged to have caused a constitutional deprivation”) (citing Rizzo v. Goode, 423 U.S. 362, 1 deprivation of a constitutional right, within the meaning of section 1983, if he does an affirmative 2 act, participates in another’s affirmative acts, or omits to perform an act which he is legal required 3 to do that causes the deprivation of which complaint is made.” Johnson v. Duffy, 588 F.2d 740, 4 743 (9th Cir. 1978) (citation omitted). 5 C. Supervisory Liability 6 Liability may not be imposed on supervisory personnel for the actions or omissions of 7 their subordinates under the theory of respondeat superior. Iqbal, 556 U.S. at 676-77; see e.g., 8 Simmons v.

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