Ojeda v. Sandoval

CourtDistrict Court, N.D. California
DecidedMarch 9, 2023
Docket3:21-cv-07479
StatusUnknown

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

Bluebook
Ojeda v. Sandoval, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MANUEL OJEDA, Case No. 21-cv-07479-EMC

8 Plaintiff, ORDER GRANTING PLAINTIFF’S 9 v. MOTION TO AMEND; AND SERVING FIRST AMENDED COMPLAINT 10 C. SANDOVAL, et al., Docket No. 10 11 Defendants.

12 13 14 Manuel Ojeda, a prisoner at High Desert State Prison, filed this pro se civil rights action 15 under 42 U.S.C. § 1983 complaining of an incident that occurred at Pelican Bay State Prison 16 (“PBSP”), where he previously was incarcerated. See Docket No. 1 (“Complaint”). The Court 17 screened the Complaint pursuant to 28 U.S.C. 1915A and dismissed it with leave to amend. See 18 Docket No. 9 (“Screening Order”). 19 Mr. Ojeda moved for leave to amend and attached his First Amended Complaint (“FAC”) 20 to that motion. Docket No. 10. Mr. Ojeda’s motion is GRANTED, although it was unnecessary 21 because the Court already gave Mr. Ojeda leave to amend in the Screening Order. 22 The FAC is now before the Court for review. For the reasons stated below, the Court 23 orders Defendants to respond to the FAC. 24 I. ANALYSIS 25 Mr. Ojeda formerly was incarcerated at Pelican Bay State Prison (“PBSP”), and his 26 allegations concern events at that prison. See generally, FAC. 27 A. Excessive Force Claim 1 applied force to his person and contended that force was excessive. See Compl. at 4-6. In the 2 Screening Order, the Court found that Mr. Ojeda had stated a cognizable claim for excessive force 3 against five correctional officers: PBSP Correctional Officers C. Sandoval, E. Rivera-Rangel, Y. 4 Lee, K. Story, and A. Maylin. See Screening Order at 5. 5 The FAC contains the same allegations as the original Complaint, see FAC at 2-4, and Mr. 6 Ojeda again states a cognizable claim against these Defendants. 7 B. Medical Needs Claim 8 In the original Complaint, Mr. Ojeda alleged that the five above-named Defendants failed 9 to seek medical care for him after the excessive force incident, although he was bleeding from the 10 head and had fainted twice. See Compl. at 6. Mr. Ojeda also alleged that two unnamed officers 11 took him to a holding cell but failed to seek medical care for hours despite Mr. Ojeda’s request for 12 such care and his obvious injuries. See id. In the Screening Order, the Court found that Mr. Ojeda 13 had stated a cognizable claim for deliberate indifference to a serious medical need against the five 14 above-named Defendants, as well as the unnamed officers. See Screening Order at 7-8. The 15 Court suggested Mr. Ojeda name the unnamed officers if possible. See id. at 8. 16 Mr. Ojeda now clarifies that those unnamed officers were PBSP Correctional Officers A. 17 Schaad and T. Wood, but the substance of his allegations against them did not change. See FAC 18 at 4. Mr. Ojeda again states a cognizable claim against these seven Defendants. 19 C. Due Process Claim 20 In the original Complaint, Mr. Ojeda alleged that he had been subject to a disciplinary 21 charge after the alleged force incident; that Defendant Sandoval had fabricated a disciplinary 22 charge and lied in the disciplinary proceedings; and that Defendant Frisk had denied him due 23 process during the disciplinary proceedings. See Compl. at 6-8. 24 1. Due Process Claim, Generally 25 In the Screening Order, the Court explained that Mr. Ojeda had not identified a 26 “deprivation of real substance,” as is required to state a due process claim, and that Mr. Ojeda 27 needed to explain what he had lost as a result of the disciplinary proceeding. See Screening Order 1 “a sentence [of] 29 month[s] in segregation”; with “loss of privilege[s]” which included the loss of 2 access to telephone and contact visitation privileges, canteen privileges, and the loss of some 3 property; “the loss of 360 day[s] of good time credit”; and the requirement that Mr. Ojeda 4 “donate” property worth $200 to the prison. See FAC at 8. 5 Two of these punishments may constitute a deprivation of “real substance,” which is 6 enough to support a due process claim at this juncture. First, Mr. Ojeda’s 29-month sentence to 7 segregation exceeds a term which the Ninth Circuit previously recognized as an “atypical and 8 significant hardship” within the meaning of Sandin. See Brown v. Oregon Dep't of Corr., 751 9 F.3d 983, 988 (9th Cir. 2014) (finding that a 27-month confinement could support a due process 10 claim); see also King v. Davis, No. 19-CV-08201-SI, 2020 WL 3961976, at *2 (N.D. Cal. July 13, 11 2020) (concluding a 180-day confinement was “an atypical and significant hardship” within the 12 meaning of Sandin). Second, Mr. Ojeda may be able to premise a due process claim on being 13 forced to “donate” property to the prison. The Ninth Circuit has held that, in certain 14 circumstances, the loss of an inmate’s property may trigger the Due Process Clause. See, e.g., 15 Shinault v. Hawks, 782 F.3d 1053 (9th Cir. 2015) (concluding the Due Process Clause was 16 implicated where prison officials froze an inmate’s trust account). Because these two punishments 17 are sufficient to suggest that Mr. Ojeda suffered a “deprivation of real substance,” the Court 18 concludes that Mr. Ojeda has stated a cognizable due process claim. 19 Although the Court does not dismiss any part of the due process claim at this point, Mr. 20 Ojeda is advised that his other two punishments may not be able to support a due process claim. 21 First, Mr. Ojeda’s loss of privileges is unlikely to constitute a deprivation of “real substance.” The 22 Ninth Circuit has considered restrictions on the privileges at issue here and held their restriction 23 does not implicate a liberty interest. See Keenan v. Hall, 83 F.3d 1083, 1092 (9th Cir. 1996) 24 (holding there is no constitutional right to canteen items), opinion amended on denial of reh’g, 135 25 F.3d 1318 (9th Cir. 1998); Anderson v. Cty. of Kern, 45 F.3d 1310, 1315 (9th Cir.) (finding “there 26 is no liberty interest in” the loss of recreational programs), opinion amended on denial of reh’g, 75 27 F.3d 448 (9th Cir. 1995); Mahon v. Prunty, 87 F.3d 1320 (9th Cir. 1996) (finding no liberty 1 App’x 689, 691 (9th Cir. 2014) (finding no liberty interest in telephone or yard privileges); see 2 also Sandin v. Conner, 515 U.S. 472, 500 (1995) (Breyer, J., dissenting) (describing the “‘[l]oss of 3 privileges’ such as “community recreation; commissary; . . . personal visits . . . ; personal phone 4 calls . . .” as “less significant” and “comparatively unimportant prisoner ‘deprivations’”). 5 However, these cases may be distinguishable because they address relatively short periods where 6 inmates lost phone and visitation privileges. See, e.g., Mahon, 87 F.3d 1320 (holding that “[t]he 7 temporary loss” of phone and visitation privileges did not implicate Sandin). 8 Second, the loss of good-time credits either is not a deprivation of real substance or may 9 require Mr. Ojeda’s due process claim to be heard in a habeas petition before it can be pursued in a 10 civil rights action. If Mr. Ojeda is serving a determinate sentence, then his damages claim is 11 Heck-barred until the disciplinary finding has been expunged. See Ramirez v. Galaza, 334 F.3d 12 850, 858-59 (9th Cir. 2003) (interpreting Neal v. Shimoda, 131 F.3d 818 (9th Cir. 1997)). This 13 would require Mr.

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Ojeda v. Sandoval, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ojeda-v-sandoval-cand-2023.