Paleti Veniale v. Washington State Department of Corrections, et al.

CourtDistrict Court, W.D. Washington
DecidedOctober 15, 2025
Docket2:25-cv-01747
StatusUnknown

This text of Paleti Veniale v. Washington State Department of Corrections, et al. (Paleti Veniale v. Washington State Department of Corrections, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Paleti Veniale v. Washington State Department of Corrections, et al., (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 PALETI VENIALE, CASE NO. 2:25-cv-01747-DGE-DWC 11 Plaintiff, ORDER DECLINING TO SERVE 12 v.

13 WASHINGTON STATE DEPARTMENT OF CORRECTIONS, et 14 al., 15 Defendants.

16 The District Court referred this action to United States Magistrate Judge David W. 17 Christel. Plaintiff Paleti Veniale, proceeding pro se and in forma pauperis, filed this civil rights 18 complaint under 42 U.S.C. § 1983. Dkts. 5, 9. Having reviewed and screened Plaintiff’s 19 Complaint under 28 U.S.C. § 1915A, the Court finds Plaintiff has failed to state a claim upon 20 which relief can be granted, but provides Plaintiff leave to file an amended pleading by 21 November 17, 2025, to cure the deficiencies identified herein. 22

24 1 I. Background 2 Plaintiff, a pretrial detainee housed at King County Jail, alleges that his rights were 3 violated when he was detained at Monroe Correctional Center (“MCC”) for fifteen days. Dkt. 9 4 at 6–7. After a hearing at MCC, all of Plaintiff’s alleged violations were dismissed. Id. at 7. And

5 when he was released from MCC, he was missing $900 that he had when he was processed there. 6 Id. 7 Based on these allegations, Plaintiff claims that he was falsely imprisoned and suffered a 8 loss of property. 9 II. Discussion 10 Under the Prison Litigation Reform Act (“PLRA”), the Court is required to screen 11 complaints brought by prisoners seeking relief against a governmental entity or officer or 12 employee of a governmental entity. 28 U.S.C. § 1915A(a). The Court must “dismiss the 13 complaint, or any portion of the complaint, if the complaint: (1) is frivolous, malicious, or fails to 14 state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant

15 who is immune from such relief.” Id. at (b); 28 U.S.C. § 1915(e)(2); see Barren v. Harrington, 16 152 F.3d 1193 (9th Cir. 1998). 17 The Court is required to liberally construe pro se documents. Estelle v. Gamble, 429 U.S. 18 97, 106 (1976). However, Federal Rule of Civil Procedure 8 requires a complaint to contain “a 19 short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. 20 P. 8(a). “Each allegation must be simple, concise, and direct.” Fed. R. Civ. P. 8(d). 21 To state a claim for relief under 42 U.S.C. § 1983, a plaintiff must show: (1) he suffered a 22 violation of rights protected by the Constitution or created by federal statute; and (2) the 23 violation was proximately caused by a person acting under color of state law. See Crumpton v.

24 1 Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). The first step in a § 1983 claim is therefore to 2 identify the specific constitutional right allegedly infringed. Albright v. Oliver, 510 U.S. 266, 271 3 (1994). 4 To satisfy the second prong, a plaintiff must allege facts showing how individually

5 named defendants caused, or personally participated in causing, the harm alleged in the 6 complaint. See Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988); Arnold v. IBM, 637 F.2d 7 1350, 1355 (9th Cir. 1981). A person subjects another to a deprivation of a constitutional right 8 when committing an affirmative act, participating in another’s affirmative act, or omitting to 9 perform an act which is legally required. Johnson v. Duffy, 588 F.2d 740, 743 (9th Cir. 1978). 10 Sweeping conclusory allegations against an official are insufficient to state a claim for relief. 11 Leer, 844 F.2d at 633. Further, a § 1983 suit cannot be based on vicarious liability alone, but 12 must allege the defendant’s own conduct violated the plaintiff’s civil rights. City of Canton v. 13 Harris, 489 U.S. 378, 385–90 (1989). 14 A. Improper Defendants

15 In the Complaint, Plaintiff sues Defendants Washington State Department of Corrections 16 (“WSDOC”), Department of Corrections West Seattle (“DOCWS”), and MCC. Dkt. 9 at 4. 17 While the Complaint is unclear, it appears Plaintiff is also suing unnamed correctional officers. 18 Id. Plaintiff cannot raise claims under § 1983 against these Defendants. 19 First, Plaintiff cannot sue Defendants WSDOC and DOCWS because the Supreme Court 20 held in Will v. Michigan Department of State Police, that “[s]tates and governmental entities that 21 are considered ‘arms of the State’ for Eleventh Amendment purposes” are not “persons” subject 22 to suit under § 1983. 491 U.S. 58, 70 (1989). Second, Plaintiff cannot sue MCC because § 1983 23 only authorizes suits against a “person” acting under the color of state law. 42 U.S.C. § 1983. As

24 1 a result, courts routinely hold that jails and prisons, such as MCC, are not persons who can be 2 sued under § 1983. See Allison v. Cal. Adult Auth., 419 F.2d 822, 823 (9th Cir. 1969) (holding 3 that California Adult Authority and San Quentin State Prison were not “persons” subject to suit 4 under § 1983). And to the extent Plaintiff is attempting to sue any unnamed correctional officers,

5 he fails because there are no allegations in the Complaint explaining how they violated his rights. 6 See Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989) (stating that a Defendant is liable under 7 42 U.S.C. § 1983 “only upon a showing of personal participation by the [D]efendant.”). 8 Therefore, if Plaintiff wishes to pursue this § 1983 action, he must provide an amended 9 pleading that names only individual Defendants and explain what each Defendant did or failed to 10 do and how the actions violated Plaintiff’s constitutional rights and caused him harm. 11 B. Instructions to Plaintiff and the Clerk 12 Due to the deficiencies described above, if Plaintiff intends to pursue a § 1983 civil rights 13 action in this Court, he must file an amended complaint and within the amended complaint, he 14 must write a short, plain statement telling the Court: (1) the constitutional right Plaintiff believes

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