Menefee v. Washington County Jail

CourtDistrict Court, D. Oregon
DecidedNovember 6, 2020
Docket3:20-cv-01499
StatusUnknown

This text of Menefee v. Washington County Jail (Menefee v. Washington County Jail) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Menefee v. Washington County Jail, (D. Or. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON LEANDREW LARONN MENEFEE, Case No. 3:20-cv-01499-AC Plaintiff, ORDER TO DISMISS v. WASHINGTON COUNTY JAIL (AND) ALL EMPLOYEE’S & SUBCONTRACTORS, Defendants. MOSMAN, Judge. Plaintiff, an adult in currently in custody at the Coffee Creek Correctional Facility1, brings this civil rights action pursuant to 42 U.S.C. § 1983. Pursuant to an Order entered this date, the court granted plaintiff’s Application to Proceed In Forma Pauperis. However, for the reasons set forth below, the court dismisses plaintiff’s Complaint.

1At the time he filed this action, plaintiff was in custody at the Washington County Jail. 1 - ORDER TO DISMISS BACKGROUND In the caption of his Complaint, plaintiff names as defendants “Washington County Jail (and) All Employee’s & Sub-Contractors.” At page two of the Complaint, however, plaintiff identifies the defendants as Lieutenant Stimler, Sgt. Munson, Deputy Rouge, and T. Martichuski.

Plaintiff alleges defendants discriminated against him based on his race and denied him his right to religious freedom. In his first claim, plaintiff alleges he has been a “target for deputies to exercise their authority (so-called)” by conducting eight cell searches in a month and by holding plaintiff for 37 hours after a judge allegedly ordered plaintiff’s release. In his second claim, plaintiff alleges he has been denied access to religious practices. Plaintiff does not allege which defendants participated in the alleged denial of access to religious practices. By way of remedy, plaintiff seeks money damages.

Plaintiff has also filed two motions for preliminary injunction. In the first motion, plaintiff contends his current custody violates his constitutional rights. By way of remedy, he seeks “injunctive relief to stop the irrepearable [sic] harm & force slavery taking place in this facility.” In the second motion, plaintiff specifically seeks immediate release from custody. Plaintiff has also filed a Motion for Appointment of Counsel. STANDARDS A district court must dismiss an action initiated by a prisoner seeking redress from a governmental entity or officer or employee, if the Court determines that the action (i) is frivolous

or malicious; (ii) fails to state a claim on which relief may be granted; or (iii) seeks monetary relief against a defendant who is immune from such relief. See 28 U.S.C. §§ 1915(e)(2) & 1915A(b). When a plaintiff is proceeding pro se, the court must construe the pleadings liberally and afford the 2 - ORDER TO DISMISS plaintiff the benefit of any doubt. Erickson v. Pardus, 551 U.S. 89, 94 (2007). Moreover, before dismissing a pro se civil rights complaint for failure to state a claim, the court supplies the plaintiff with a statement of the complaint’s deficiencies. Karim-Panahi v. Los Angeles Police Dept., 839 F.2d 621, 623-24 (9th Cir. 1988); Eldridge v. Block, 832 F.2d 1132, 1136 (9th Cir. 1987). A pro se

litigant will be given leave to amend his or her complaint unless it is clear that the deficiencies of the complaint cannot be cured by amendment. Karim-Panahi, 839 F.2d at 623; Lopez v. Smith, 203 F.3d 1122, 1130-31 (9th Cir. 2000). DISCUSSION I. Procedural Deficiencies Pursuant to Rule 10(a) of the Federal Rules of Civil Procedure, “[t]he title of the complaint must name all the parties; the title of other pleadings, after naming the first party on each side, may

refer generally to other parties.” As noted, the defendants identified in the caption of plaintiff’s Complaint differ from those identified at page two. Should plaintiff file an Amended Complaint curing the substantive deficiencies noted below, the Court advises plaintiff to clearly identify all intended defendants in the caption thereof. II. Substantive Deficiencies To state a claim under 42 U.S.C. § 1983, a complaint must allege that a defendant, while acting under color of state law, caused a deprivation of the plaintiff’s federal rights. 42 U.S.C. § 1983; West v. Atkins, 487 U.S. 42, 48 (1988) (citations omitted); Taylor v. List, 880 F.2d 1040, 1045

(9th Cir. 1989) (citation omitted). A § 1983 plaintiff must establish both causation-in-fact and proximate (i.e., legal) causation. See Harper v. City of Los Angeles, 533 F.3d 1010, 1026 (9th Cir. 2008). Allegations regarding Section 1983 causation “must be individualized and focus on the duties 3 - ORDER TO DISMISS and responsibilities of each individual defendant whose acts or omissions are alleged to have caused a constitutional deprivation.” Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988) (citations omitted). “Sweeping conclusory allegations [regarding causation] will not suffice[.]” Id. (citation omitted). In order to state a § 1983 claim, a plaintiff must allege facts giving rise to a reasonable

inference that the named defendants were personally involved in the alleged constitutional violation. Taylor, 880 F.2d at 1045. Here, plaintiff’s denial of religious freedom claim fails to allege facts giving rise to a reasonable inference that any of the named defendants were personally involved in the alleged violation of his rights; plaintiff does not allege who was personally involved in the decision to deny him access to religious services. Accordingly, plaintiff fails to state a claim for denial of his First Amendment rights upon which relief may be granted under § 1983. Under the Equal Protection Clause, “the State must govern impartially.” McQueary v.

Blodgett, 924 F.2d 829, 834 (9th Cir .1991). The state’s laws and rules must be applied evenhandedly to all persons within the jurisdiction. Id. (citing Jones v. Helms, 452 U.S. 412, 423 (1981)). The laws and rules must also be evenhanded as actually applied to specific individuals. Id. at 834-35. Ultimately, the Equal Protection Clause “‘guarantees equal laws, not equal results.’” Id. at 835 (quoting Personnel Adm’r v. Feeney, 442 U.S. 256, 273 (1979)). A plaintiff who alleges denial of equal protection bears the burden of establishing a prima facie case of invidious discrimination. See United States v. Estrada-Plata, 57 F.3d 757, 760 (9th Cir.1995). In the present case, plaintiff’s conclusory allegation of an equal protection violation lacks

factual support.

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Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Personnel Administrator of Mass. v. Feeney
442 U.S. 256 (Supreme Court, 1979)
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452 U.S. 412 (Supreme Court, 1981)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Wilkinson v. Dotson
544 U.S. 74 (Supreme Court, 2005)
Erickson v. Pardus
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Harry Franklin v. Ms. Murphy and Hoyt Cupp
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Edward G. Eldridge v. Sherman Block
832 F.2d 1132 (Ninth Circuit, 1987)
United States v. Martin Estrada-Plata
57 F.3d 757 (Ninth Circuit, 1995)
Harper v. City of Los Angeles
533 F.3d 1010 (Ninth Circuit, 2008)
Lopez v. Smith
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Taylor v. List
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Menefee v. Washington County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/menefee-v-washington-county-jail-ord-2020.