(PC) Hill v. State of California

CourtDistrict Court, E.D. California
DecidedFebruary 14, 2025
Docket1:24-cv-01284
StatusUnknown

This text of (PC) Hill v. State of California ((PC) Hill v. State of California) 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) Hill v. State of California, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 SHAWN CODY HILL, No. 1:24-cv-01284-SAB (PC) 12 Plaintiff, ORDER DIRECTING CLERK OF COURT TO RANDOMLY ASSIGN A DISTRICT 13 v. JUDGE TO THIS ACTION 14 STATE OF CALIFORNIA, et al., FINDINGS AND RECOMMENDATIONS RECOMMENDING DISMISSAL OF 15 ACTION Defendants. 16 (ECF No. 8) 17 18 19 Plaintiff is proceeding pro se and in forma pauperis in this action filed pursuant to 42 20 U.S.C. § 1983. 21 Plaintiff’s complaint in this action was filed on October 22, 2024. (ECF No. 1.) 22 On December 9, 2024, the Court screened the complaint, found that Plaintiff failed to state 23 a cognizable claim for relief, and granted Plaintiff thirty days to file an amended complaint. 24 (ECF No. 7.) 25 Plaintiff failed to file an amended complaint or otherwise respond to the December 9, 26 2024 order. Therefore, on January 21, 2025, the Court issued an order for Plaintiff to show cause 27 why the action should not be dismissed. (ECF No. 8.) Plaintiff has failed to respond to the order 28 to show cause and the time to do so has now passed. Accordingly, dismissal of the action is 1 warranted. 2 I. 3 SCREENING REQUIREMENT 4 The Court is required to screen complaints brought by prisoners seeking relief against a 5 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 6 Court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 7 “frivolous or malicious,” that “fail[] to state a claim on which relief may be granted,” or that 8 “seek[] monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 9 1915(e)(2)(B); see also 28 U.S.C. § 1915A(b). 10 A complaint must contain “a short and plain statement of the claim showing that the 11 pleader is entitled to relief. . . .” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not 12 required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere 13 conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell 14 Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Moreover, Plaintiff must demonstrate 15 that each defendant personally participated in the deprivation of Plaintiff’s rights. Jones v. 16 Williams, 297 F.3d 930, 934 (9th Cir. 2002). 17 Prisoners proceeding pro se in civil rights actions are entitled to have their pleadings 18 liberally construed and to have any doubt resolved in their favor. Wilhelm v. Rotman, 680 F.3d 19 1113, 1121 (9th Cir. 2012) (citations omitted). To survive screening, Plaintiff’s claims must be 20 facially plausible, which requires sufficient factual detail to allow the Court to reasonably infer 21 that each named defendant is liable for the misconduct alleged. Iqbal, 556 U.S. at 678-79; Moss 22 v. U.S. Secret Service, 572 F.3d 962, 969 (9th Cir. 2009). The “sheer possibility that a defendant 23 has acted unlawfully” is not sufficient, and “facts that are ‘merely consistent with’ a defendant’s 24 liability” falls short of satisfying the plausibility standard. Iqbal, 556 U.S. at 678; Moss, 572 F.3d 25 at 969. 26 II. 27 COMPLAINT ALLEGATIONS 28 The Court accepts Plaintiff’s allegations in the complaint as true only for the purpose of the 1 screening requirement under 28 U.S.C. § 1915. 2 Plaintiff was assaulted in his cell while housed at Lerdo pretrial facility in a mental health 3 unit. The physical altercation resulted in Plaintiff having surgery on his right hand. The facility 4 no longer has an administrative segregation unit to house the mentally ill inmates resulting in all 5 inmates being housed together. The facility also does not allow basic materials for the practice of 6 Plaintiff’s Asatru religious beliefs. 7 III. 8 DISCUSSION 9 “[P]retrial detainees ... possess greater constitutional rights than prisoners,” Stone v. City 10 and County of San Francisco, 968 F.2d 850, 857 n.10 (9th Cir. 1992), and are entitled to 11 treatment more considerate than that afforded individuals who have been convicted of a crime, 12 Jones v. Blanas, 393 F.3d 918, 931-32 (9th Cir. 2004). Constitutional claims of a pretrial 13 detainee “arise[ ] from the due process clause of the [F]ourteenth [A]mendment and not from the 14 [E]ighth [A]mendment prohibition against cruel and unusual punishment.” Jones v. Johnson, 781 15 F.2d 769, 771 (9th Cir. 1986) (citing Bell v. Wolfish, 441 U.S. 520, 573 n.16 (1979)), overruled 16 on other grounds by Peralta v. Dillard, 744 F.3d 1076 (9th Cir. 2014). “[T]he more protective 17 [F]ourteenth [A]mendment standard applies to conditions of confinement when detainees ... have 18 not been convicted” of a crime. Gary H. v. Hegstrom, 831 F.2d 1430, 1432 (9th Cir. 1987). 19 The Fourteenth Amendment requires the government to do more than provide minimal 20 necessities to non-convicted detainees. Jones v. Blanas, 393 F.3d at 931. Under the Due Process 21 Clause, pretrial detainees have a right to be free from jail conditions or restrictions that “amount 22 to punishment.” Bell, 441 U.S. at 535-37; see also Pierce v. Cnty. of Orange, 526 F.3d 1190, 23 1205 (9th Cir. 2008). “This standard differs significantly from the standard relevant to convicted 24 prisoners, who may be subject to punishment so long as it does not violate the Eighth 25 Amendment's bar against cruel and unusual punishment.” Pierce, 526 F.3d at 1205. 26 A. State of California 27 “Suits against state officials in their official capacity ... should be treated as suits against 28 the State.” Hafer v. Melo, 502 U.S. 21, 25 (1991); Holley v. Cal. Dep’t of Corr., 599 F.3d 1108, 1 1111 (9th Cir. 2010) (treating prisoner's suit against state officials in their official capacities as a 2 suit against the state of California). An official capacity suit “represent[s] only another way of 3 pleading an action against an entity of which an officer is an agent.” Kentucky v. Graham, 473 4 U.S. 159, 165 (1985) (citation omitted). Such a suit “is not a suit against the official personally, 5 for the real party in interest is the entity.” Id. at 166 (emphasis in original). 6 “The Eleventh Amendment bars suits for money damages in federal court against a state, 7 its agencies, and state officials acting in their official capacities.” Aholelei v. Dep’t of Public 8 Safety, 488 F.3d 1144, 1147 (9th Cir. 2007). Indeed, the Eleventh Amendment prohibits federal 9 courts from hearing a Section 1983 lawsuit in which damages or injunctive relief is sought against 10 a state, its agencies (such as CDCR) or individual prisons, absent “a waiver by the state or a valid 11 congressional override....” Dittman v. California, 191 F.3d 1020, 1025 (9th Cir. 1999).

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Bluebook (online)
(PC) Hill v. State of California, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-hill-v-state-of-california-caed-2025.