(PC) Haywood v. Reed

District Court, E.D. California·Decided November 6, 2023·No. 2:23-cv-00078·Unknown

Opinion

CAMERON LEE HAYWOOD, No. 2:23-cv-0078 DB P Plaintiff, v. ORDER Defendant. Plaintiff is a state prisoner proceeding pro se with a civil rights action pursuant to 42 U.S.C. § 1983. Plaintiff claims defendants violated his Eighth Amendment rights by using excessive force against him and failing to protect him. Presently before the court is plaintiff’s amended complaint (ECF No. 11) for screening. For the reasons set forth below, the undersigned will give plaintiff the option to proceed immediately with his cognizable claims or to amend the complaint. SCREENING I. Legal Standards The court is required to screen complaints brought by prisoners seeking relief against a governmental entity or an officer or employee of a governmental entity. See 28 U.S.C. § 1915A(a). The court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek monetary relief from a defendant who is immune from such relief. See 28 U.S.C. § 1915A(b)(1) & (2). A claim is legally frivolous when it lacks an arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 (1989); Franklin v. Murphy, 745 F.2d 1221, 1227-28 (9th Cir. 1984). The court may, therefore, dismiss a claim as frivolous where it is based on an indisputably meritless legal theory or where the factual contentions are clearly baseless. Neitzke, 490 U.S. at 327. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable legal and factual basis. See Franklin, 745 F.2d at 1227. Rule 8(a)(2) of the Federal Rules of Civil Procedure “requires only ‘a short and plain statement of the claim showing that the pleader is entitled to relief,’ in order to ‘give the defendant fair notice of what the . . . claim is and the grounds upon which it rests.’” Bell AtlanticCorp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957)). However, in order to survive dismissal for failure to state a claim a complaint must contain more than “a formulaic recitation of the elements of a cause of action;” it must contain factual allegations sufficient “to raise a right to relief above the speculative level.” Bell Atlantic, 550 U.S. at 555. In reviewing a complaint under this standard, the court must accept as true the allegations of the complaint in question, Hospital Bldg. Co. v. Rex Hospital Trustees, 425 U.S. 738, 740 (1976), construe the pleading in the light most favorable to the plaintiff, and resolve all doubts in the plaintiff’s favor. Jenkins v. McKeithen, 395 U.S. 411, 421 (1969). The Civil Rights Act under which this action was filed provides as follows: Every person who, under color of [state law] . . . subjects, or causes to be subjected, any citizen of the United States . . . to the deprivation of any rights, privileges, or immunities secured by the Constitution . . . shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress. 42 U.S.C. § 1983. The statute requires that there be an actual connection or link between the actions of the defendants and the deprivation alleged to have been suffered by plaintiff. See Monell v. Dept. of Social Servs., 436 U.S. 658 (1978); Rizzo v. Goode, 423 U.S. 362 (1976). “A person ‘subjects’ another to the deprivation of a constitutional right, within the meaning of § 1983, if he does an affirmative act, participates in another's affirmative acts or omits to perform an act which he is legally required to do that causes the deprivation of which complaint is made.” Johnson v. Duffy, 588 F.2d 740, 743 (9th Cir. 1978). Moreover, supervisory personnel are generally not liable under § 1983 for the actions of their employees under a theory of respondeat superior and, therefore, when a named defendant holds a supervisorial position, the causal link between him and the claimed constitutional violation must be specifically alleged. See Fayle v. Stapley, 607 F.2d 858, 862 (9th Cir. 1979); Mosher v. Saalfeld, 589 F.2d 438, 441 (9th Cir. 1978). Vague and conclusory allegations concerning the involvement of official personnel in civil rights violations are not sufficient. See Ivey v. Board of Regents, 673 F.2d 266, 268 (9th Cir. 1982). II. Allegations in the Complaint Plaintiff states the events giving rise to the claim occurred while he was incarcerated at California State Prison, Sacramento (“SAC”). (ECF No. 11 at 1.) Plaintiff has identified SAC correctional officer Reed along with several John Doe defendants. (Id. at 1, 2.) Plaintiff states he arrived at SAC on January 16, 2020. (Id. at 3.) Plaintiff claims John Doe #1 failed to conduct an interview to determine a proper housing assignment. He further states Doe #1 intentionally assigned him to an incorrect housing unit. (Id.) Plaintiff was in Receiving and Release when officer Reed and John Doe #2 came to escort him to a cell on A-Facility. (Id.) Plaintiff told Reed and Doe #2 that he should be going to A- Facility – 5 Block Administrative Segregation. Reed told plaintiff that he was going to cell 214 on A-Facility. When they arrived at A-Facility plaintiff told Reed again that he was placing him in the wrong housing unit. Reed and Doe #2 hit plaintiff and threw him to the ground. While plaintiff was on the ground Doe #2 pulled his hair and hit him in the head. (Id.) Plaintiff alleges that Reed “using his fingers rammed them thru [sic] [plaintiff’s] paper jumpsuit and into [his] rectum . . . Then moved them around – He then removed his fingers and using his state issued pepper spray – sprayed [plaintiff] on the opening and in [his] rectum.” (Id.) //// Reed asked if plaintiff had enough, and plaintiff responded, “I’m cool.” (Id. at 4.) Doe #2 and Reed helped plaintiff to his feet and escorted him to the front of cell #214. Plaintiff was pushed into cell #214 which was occupied by inmate McCastle. (Id.) After Reed removed plaintiff’s handcuffs, “a physical altercation began” between plaintiff and McCastle lasting several minutes. Plaintiff heard an unknown officer place a state issued mattress in front of the cell. (Id.) The officer then opened the cell door slightly so that plaintiff could pull in the mattress, then closed the cell door. Plaintiff found a weapon in the mattress. He states he stayed awake all night in fear his cellmate would attack him again. (Id.) The following day, January 17, 2020, an unknown officer came to the cell door. Plaintiff asked why he was given a mattress that was ripped open with a mattress inside. (Id.) The officer did not respond.

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(PC) Haywood v. Reed, (E.D. Cal. 2023).

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Jenkins v. McKeithen
395 U.S. 411 (Supreme Court, 1969)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Ingraham v. Wright
430 U.S. 651 (Supreme Court, 1977)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Whitley v. Albers
475 U.S. 312 (Supreme Court, 1986)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Wilson v. Seiter
501 U.S. 294 (Supreme Court, 1991)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Swierkiewicz v. Sorema N. A.
534 U.S. 506 (Supreme Court, 2002)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ivey v. Board of Regents of University of Alaska
673 F.2d 266 (Second Circuit, 1982)
Harry Franklin v. Ms. Murphy and Hoyt Cupp
745 F.2d 1221 (Ninth Circuit, 1984)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Frost v. Agnos
152 F.3d 1124 (Ninth Circuit, 1998)
Johnson v. Duffy
588 F.2d 740 (Ninth Circuit, 1978)