(PC) Craig v. Jones

CourtDistrict Court, E.D. California
DecidedMay 23, 2024
Docket2:22-cv-01874
StatusUnknown

This text of (PC) Craig v. Jones ((PC) Craig v. Jones) 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) Craig v. Jones, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 MICHAEL A. CRAIG, No. 2:22-cv-01874 DAD- AC 12 Plaintiff, 13 v. ORDER 14 GENA JONES, et al., 15 Defendants. 16 17 Plaintiff is a state prisoner proceeding without counsel. Plaintiff seeks relief pursuant to 18 42 U.S.C. § 1983 and has paid the filing fee for this action. This proceeding was referred to this 19 court pursuant to 28 U.S.C. § 636(b)(1) and Local Rule 302. Plaintiff’s amended complaint and 20 motion for the appointment of counsel are now before the court. 21 I. Motion for the Appointment of Counsel 22 Plaintiff has requested appointment of counsel. The United States Supreme Court has 23 ruled that district courts lack authority to require counsel to represent indigent prisoners in § 1983 24 cases. Mallard v. United States Dist. Court, 490 U.S. 296, 298 (1989). In certain exceptional 25 circumstances, the district court may request the voluntary assistance of counsel pursuant to 28 26 U.S.C. § 1915(e)(1). Terrell v. Brewer, 935 F.2d 1015, 1017 (9th Cir. 1991); Wood v. 27 Housewright, 900 F.2d 1332, 1335-36 (9th Cir. 1990). 28 The test for exceptional circumstances requires the court to evaluate the plaintiff’s 1 likelihood of success on the merits and the ability of the plaintiff to articulate his claims pro se in 2 light of the complexity of the legal issues involved. See Wilborn v. Escalderon, 789 F.2d 1328, 3 1331 (9th Cir. 1986); Weygandt v. Look, 718 F.2d 952, 954 (9th Cir. 1983). Circumstances 4 common to most prisoners, such as lack of legal education and limited law library access, do not 5 establish exceptional circumstances that would warrant a request for voluntary assistance of 6 counsel. In the present case, the court does not find the required exceptional circumstances. 7 II. Screening Requirement 8 The court is required to screen complaints brought by prisoners seeking relief against a 9 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 10 court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 11 “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek 12 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1), (2). 13 A claim is legally frivolous when it lacks an arguable basis either in law or in fact. 14 Neitzke v. Williams, 490 U.S. 319, 325 (1989); Franklin v. Murphy, 745 F.2d 1221, 1227-28 (9th 15 Cir. 1984). The court may, therefore, dismiss a claim as frivolous where it is based on an 16 indisputably meritless legal theory or where the factual contentions are clearly baseless. Neitzke, 17 490 U.S. at 327. The critical inquiry is whether a constitutional claim, however inartfully 18 pleaded, has an arguable legal and factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th 19 Cir. 1989); Franklin, 745 F.2d at 1227. 20 A complaint, or portion thereof, should only be dismissed for failure to state a claim upon 21 which relief may be granted if it appears beyond doubt that plaintiff can prove no set of facts in 22 support of the claim or claims that would entitle him to relief. Hishon v. King & Spalding, 467 23 U.S. 69, 73 (1984) (citing Conley v. Gibson, 355 U.S. 41, 45-46 (1957)); Palmer v. Roosevelt 24 Lake Log Owners Ass’n, 651 F.2d 1289, 1294 (9th Cir. 1981). In reviewing a complaint under 25 this standard, the court must accept as true the allegations of the complaint in question, Hosp. 26 Bldg. Co. v. Rex Hosp. Trustees, 425 U.S. 738, 740 (1976), construe the pleading in the light 27 most favorable to the plaintiff, and resolve all doubts in the plaintiff's favor, Jenkins v. 28 McKeithen, 395 U.S. 411, 421 (1969). 1 III. Allegations of the Amended Complaint 2 At all times relevant to the allegations in the amended complaint, plaintiff was a disabled 3 inmate at the California Health Care Facility (“CHCF”). Plaintiff’s specific disability requires 4 him to use a wheelchair. The 93 page amended complaint in this case is based on events 5 occurring between July 2018 and December 2022. Plaintiff sues over 20 different prison officials 6 ranging from supervisory staff such as the prison warden, correctional officers, and various 7 medical staff at CHCF. The amended complaint consists of a lengthy run-on narrative about a 8 vast array of issues including plaintiff’s medical care, his disciplinary proceedings, the condition 9 of the water at the prison, his property that was confiscated, as well as the use of violence against 10 him by other inmates. 11 IV. Legal Standards 12 The following legal standards are provided based on plaintiff’s pro se status as well as the 13 nature of the allegations in the complaint. 14 A. Linkage 15 The civil rights statute requires that there be an actual connection or link between the 16 actions of the defendants and the deprivation alleged to have been suffered by plaintiff. See 17 Monell v. Department of Social Services, 436 U.S. 658 (1978); Rizzo v. Goode, 423 U.S. 362 18 (1976). The Ninth Circuit has held that “[a] person ‘subjects' another to the deprivation of a 19 constitutional right, within the meaning of section 1983, if he does an affirmative act, participates 20 in another's affirmative acts or omits to perform an act which he is legally required to do that 21 causes the deprivation of which complaint is made.” Johnson v. Duffy, 588 F.2d 740, 743 (9th 22 Cir. 1978) (citation omitted). In order to state a claim for relief under section 1983, plaintiff must 23 link each named defendant with some affirmative act or omission that demonstrates a violation of 24 plaintiff's federal rights. 25 B. Joinder of Parties and Claims 26 A plaintiff may properly assert multiple claims against a single defendant in a civil action. 27 Fed. Rule Civ. P. 18. In addition, a plaintiff may join multiple defendants in one action where 28 “any right to relief is asserted against them jointly, severally, or in the alternative with respect to 1 or arising out of the same transaction, occurrence, or series of transactions and occurrences” and 2 “any question of law or fact common to all defendants will arise in the action.” Fed. R. Civ. P. 3 20(a)(2).

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(PC) Craig v. Jones, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-craig-v-jones-caed-2024.