(PC) Castro v. Covello

CourtDistrict Court, E.D. California
DecidedJanuary 30, 2025
Docket2:23-cv-00694
StatusUnknown

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

Bluebook
(PC) Castro v. Covello, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 JOSEPH ANTHONY CASTRO, No. 2:23-cv-0694 DC AC P 12 Plaintiff, 13 v. ORDER AND FINDINGS AND RECOMMENDATIONS 14 COVELLO, et al., 15 Defendants. 16 17 Plaintiff, a state prisoner proceeding without an attorney, seeks relief pursuant to 42 18 U.S.C. § 1983. Pending before the court are plaintiff’s first amended complaint (“FAC”) and 19 plaintiff’s motion to consolidate cases. ECF Nos. 22, 23. 20 I. Background 21 A. Original Complaint 22 The original complaint alleged that defendants Covello and Does 1-5 violated plaintiff’s 23 rights under the First and Fourteenth Amendments and state tort law. ECF No. 1. Specifically, 24 plaintiff alleged that between 2020 and 2022, Does 2-5 knowingly and willingly opened his legal 25 mail on approximately four separate occasions outside of his presence. Id. at 5. Plaintiff asserted 26 that the mail that was opened by Does 2-5 was clearly identified as legal/confidential mail and 27 was correspondence between him, his lawyer, and his case manager with respect to an application 28 //// 1 for a Franklin hearing,1 and resulted in plaintiff’s delayed response. Id. Plaintiff attached a 2 CDCR appeals claim decision granting his appeal based on assertions that his incoming 3 confidential mail had been received through regular mail and was opened outside of his presence 4 in violation of California Code of Regulations, Title 15, section 3141 and 3142. Id. at 9. Plaintiff 5 also alleged that the actions of Does 2-5 were the result of a failure by Covello (the warden) and 6 Doe 1 (a mailroom supervisor) failure to train mailroom staff regarding the proper handling of 7 legal mail. Id. at 6-7. Plaintiff asserted that after each violation staff were immediately notified, 8 and that each time he sent a GA-22 form, a supervisor responded by acknowledging the legal mail 9 violation and making promises to retrain staff so that the situation would not happen again. Id. 10 Despite such promises, mailroom staff continued to open plaintiff’s legal mail outside of his 11 presence. Id. 12 B. Screening Order 13 On September 30, 2024, the court screened plaintiff’s original complaint and found that 14 plaintiff had stated First Amendment claims against Does 2-5, mailroom staff, and a deliberate 15 indifference claim against Doe 1, mailroom supervisor, but had not stated any claims against 16 Covello. ECF No. 12 at 4-6. Plaintiff was given the option of amending the complaint or 17 proceeding immediately on the cognizable claims against Does 1-5, but was advised that service 18 would not be ordered until plaintiff had identified Does 1-5 and filed either an amended 19 complaint that names the defendants or a motion to substitute named defendants for Doe 20 defendants. Id. at 4-5. Plaintiff informed the court that he wanted to amend the complaint. ECF 21 No. 16. 22 C. First Amended Complaint 23 Plaintiff alleges that Susan Townsend, mailroom supervisor, violated plaintiff’s rights by 24 failing to train mailroom staff on how to handle confidential/legal/ privileged mail and by 25 allowing them to continue to open his confidential/legal/privileged mail. ECF No. 22 at 3, 5, 6. 26

27 1 It appears that plaintiff was referring to a hearing pursuant to People v. Franklin, 63 Cal. 4th 261 (2016), under which a prisoner may make a record of information relevant to his eventual 28 youth offender parole hearing. 1 Plaintiff claims that mailroom staff violated his First Amendment rights by opening numerous 2 letters from Human Services—not from an attorney—outside of his presence. Id. at 3. The 3 letters contained child protective services reports that related to his Franklin hearing but were not 4 from an attorney. Id. He alleges this happened five times, and that after each time he sent a 5 CDCR GA Form 22 and received a response from Townsend acknowledging his legal mailed was 6 opened outside his presence and that “staff would be properly trained” and it “would not occur 7 again.” Id. at 3, 5. 8 Plaintiff further alleges that because he filed grievances for the mail violations and named 9 Covello in said grievances, Covello was put on notice of the ongoing violations, and he should be 10 held responsible for failing to stop the ongoing violations and for failing to require Townsend to 11 train mailroom staff. Id. at 5. Plaintiff asserts that the fact that he had to file two separate 12 lawsuits based on ongoing violations, establishes an ongoing pattern. Id. Plaintiff claims that, 13 because of Townsend and Covello’s violations, pages from the letters were lost and never 14 recovered, he was unable to deliver the complete reports to his attorney for his Franklin hearing, 15 and his mental health declined. Id. at 3, 5-7. 16 D. Motion to Consolidate 17 Plaintiff seeks to consolidate the present case, Case No. 23-cv-0694 DC AC (“Castro I”), 18 with Case No. 24-cv-0928 CKD (“Castro II”). ECF No. 23. Plaintiff asserts that consolidation 19 would save the court time and resources “[b]ecause the claims are similar & all parties involved 20 are the same.” Id. In Castro II, plaintiff presently alleges claims against defendants Townsend 21 and Covello for opening plaintiff’s confidential/legal/privileged mail outside his presence after he 22 filed Castro I. See Case No. 2:24-cv-0928-CDK, ECF No. 15. 23 II. Statutory Screening of Prisoner Complaints 24 The court is required to screen complaints brought by prisoners seeking relief against “a 25 governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A(a). 26 The court must dismiss a complaint or portion thereof if the prisoner has raised claims that are 27 “frivolous, malicious, or fail[] to state a claim upon which relief may be granted,” or that “seek[] 28 monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b). 1 A claim “is [legally] frivolous where it lacks an arguable basis either in law or in fact.” 2 Neitzke v. Williams, 490 U.S. 319, 325 (1989); Franklin v. Murphy, 745 F.2d 1221, 1227-28 (9th 3 Cir. 1984). “[A] judge may dismiss . . . claims which are ‘based on indisputably meritless legal 4 theories’ or whose ‘factual contentions are clearly baseless.’” Jackson v. Arizona, 885 F.2d 639, 5 640 (9th Cir. 1989) (quoting Neitzke, 490 U.S. at 327), superseded by statute on other grounds as 6 stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000). The critical inquiry is whether a 7 constitutional claim, however inartfully pleaded, has an arguable legal and factual basis. 8 Franklin, 745 F.2d at 1227-28 (citations omitted). 9 “Federal Rule of Civil Procedure 8(a)(2) requires only ‘a short and plain statement of the 10 claim showing that the pleader is entitled to relief,’ in order to ‘give the defendant fair notice of 11 what the . . . claim is and the grounds upon which it rests.’” Bell Atl. Corp. v. Twombly, 550 12 U.S. 544, 555 (2007) (alteration in original) (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957)).

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Bluebook (online)
(PC) Castro v. Covello, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-castro-v-covello-caed-2025.