Leischner v. Coeur D'Alene County Sheriff's Office

District Court, D. Idaho·Decided December 30, 2024·No. 2:24-cv-00395·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

DALE RUSSELL LEISHNER, Case No. 2:24-cv-00395-BLW Plaintiff, INITIAL REVIEW ORDER v. BY SCREENING JUDGE

COEUR D’ALENE COUNTY SHERIFF’S OFFICE, RAUL R. LABRADOR, ROBERT B. NORRIS, JEFF NYE,

Defendants.

Plaintiff Dale Russell Leischner (“Plaintiff”) asserts prisoner civil rights and disabilities claims in his Complaint. Dkt. 3. The case was transferred to this Court via a venue transfer from the United States District Court for the District of Montana. Dkt. 9. The Court must review complaints filed by prisoners seeking relief against state actors to determine whether summary dismissal is appropriate. See 28 U.S.C. § 1915A. Having reviewed Plaintiff’s Complaint, the Court issues the following Order requiring amendment. REVIEW OF COMPLAINT 1. Standard of Law for Screening A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). The Court liberally construes the pleadings to determine whether a case should be dismissed. Under Rule 8 and 28 U.S.C. §§ 1915 and 1915A, the Court may dismiss some or all of the claims in a complaint for any of the following reasons:

• “insufficient facts under a cognizable legal theory,” Robertson v. Dean Witter Reynolds, Inc., 749 F.2d 530, 534 (9th Cir. 1984), meaning that the factual assertions, taken as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged,” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); • “lack of a cognizable legal theory,” Robertson, 749 F.2d at 534, including that the complaint fails to state a claim upon which relief may be granted, 28 U.S.C. § 1915(e)(2)(B), or the Court applies a procedural bar sua sponte (on its own), see, e.g., Hebrard v. Nofziger, 90 F.4th 1000, 1006 (9th Cir. 2024) (affirming dismissal based on Heck v. Humphrey, 512 U.S. 477 (1994)); • frivolousness or maliciousness, 28 U.S.C. § 1915(e)(2)(B); or • seeking monetary relief from a defendant who is immune from such relief. Id. 2. Discussion of Section 1983 Civil Rights Claims To state a claim under 42 U.S.C. § 1983, the civil rights statute, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). Here, Plaintiff is a Montana prisoner who was transported to the Kootenai County Jail (“jail”) in Coeur d’Alene, Idaho, to respond to Idaho state criminal charges in 2024. His claims arise from his stay at the jail. A. Eighth or Fourteenth Amendment Exercise Claims Plaintiff alleges that he had no fresh air or recreation for 90 days while incarcerated at the Kootenai County Jail. His status as both a convicted felon and a

pretrial detainee calls into question the standard of law to be applied to his claims. A pretrial detainee’s claims arise under the Fourteenth Amendment Due Process Clause, which prohibits all “punishment” of a pre-conviction detainee, rather than the Eighth Amendment which prohibits only cruel and unusual punishment of a convicted prisoner. Bell v. Wolfish, 441 U.S. 520, 535 n.16 (1971). No precedential Ninth Circuit

case has addressed whether a convicted felon already serving a sentence should be treated as a pretrial detainee on a new probation or parole charge or as a convicted felon. In an unpublished case, the Ninth Circuit determined that, where a convicted felon was newly being held as a pretrial detainee on a parole violation, “[w]e have little difficulty concluding that the Eighth Amendment provides the proper standard for [the parole

violator].” Flores v. Mesenbourg, 116 F.3d 483 (9th Cir. 1997) (unpubl.); accord, Henderson v. Fries, 2011 WL 2198312 at * 9, n. 2 (N.D. Ind. 2011) (collecting cases); Cleveland v. Los Angeles Cnty. Sheriffs Dep't, No. CV 15-1399-DSF (GJS), 2015 WL 13907452, at *1 (C.D. Cal. Dec. 23, 2015) (leaning toward Eighth Amendment but finding that the claim failed under either standard). This Court need not decide this issue

today, but notes only that Plaintiff has not stated a cognizable claim under either standard. An Eighth Amendment claim has two components. The first is an objective showing: Plaintiff must allege facts showing that he is “incarcerated under conditions posing a substantial risk of serious harm.” Farmer v. Brennan, 511 U.S. 825, 834 (1994)

(internal quotation marks omitted). The second component is a subjective showing: that Defendant acted with “deliberate indifference,” which is “more than mere negligence,” but “less than acts or omissions for the very purpose of causing harm or with knowledge that harm will result.” Id. at 835. To exhibit deliberate indifference, a jail official “must both be

aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he [or she] must also draw the inference,” id. at 837, and then the official must recklessly disregard the excessive risk to the inmate’s health or safety, id. at 838. Similarly, pretrial detainees’ conditions-of-confinement claims are analyzed under

an “objective deliberate indifference standard.” Gordon v. County of Orange, 888 F.3d 1118, 1124-25 (9th Cir. 2018). Under that standard, a detainee must establish the following elements: “(1) The defendant made an intentional decision with respect to the conditions [of confinement]; (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 official in the circumstances would have appreciated the high degree of risk involved—making the consequences of the defendant’s conduct obvious; and (4) By not taking such measures, the defendant caused the plaintiff’s injuries.” Sandoval v. Cnty. of San Diego, 985 F.3d 657, 669 (9th Cir.) (citation omitted). To satisfy the third element, the plaintiff must show that the defendant’s actions were “objectively unreasonable,” which requires a showing of “more

than negligence but less than subjective intent—something akin to reckless disregard.” Id. (citation omitted). Exercise is “one of the basic human necessities” protected by the Constitution.” May v. Baldwin, 109 F.3d 557, 565 (9th Cir. 1997) (quoting LeMaire v. Maass, 12 F.3d 1444, 1457 (9th Cir.

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Leischner v. Coeur D'Alene County Sheriff's Office, (D. Idaho 2024).

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