(PC) Knight v. St. Andre

District Court, E.D. California·Decided June 3, 2024·No. 2:23-cv-00177·Unknown

Opinion

CLARENCE V. KNIGHT, No. 2:23-cv-0177 DAD DB P Plaintiff, v. ORDER R. ST. ANDRE, et al., Defendants. Plaintiff, a state prisoner proceeding pro se, filed this civil rights action pursuant to 42 U.S.C. § 1983. Before the court is plaintiff’s second amended complaint for screening. For the reasons set forth below, this court finds plaintiff has stated a potentially cognizable claim against defendant Watkins but does not state any other claims. Those other claims and defendants will be dismissed. Plaintiff will be given a choice. He may either proceed immediately on his claim against defendant Watkins or he may file a third amended complaint. I. Legal Standards for §1983 Claims As described in this court’s prior screening orders, the court is required to screen complaints brought by prisoners to determine whether they sufficiently state claims under 42 U.S.C. § 1983. 28 U.S.C. § 1915A(a). The prisoner must plead an arguable legal and factual basis for each claim in order to survive dismissal. Franklin v. Murphy, 745 F.2d 1221, 1227-28 (9th Cir. 1984). In addition, the prisoner must demonstrate a link between the actions of each defendant and the deprivation of his rights. Monell v. Dept. of Social Servs., 436 U.S. 658 (1978). “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). II. Allegations in the Second Amended Complaint Plaintiff complains of conduct that occurred in 2022 when he was incarcerated at High Desert State Prison (“HDSP”). He identifies the following defendants: (1) R. St. Andre, Warden; (2) N. Miller, Correctional Officer (“CO”); (3) G. Watkins, Correctional Lieutenant; (4) Nate Smith, Correctional Sergeant; (5) D. Acosta, Correctional Officer; (6) M. Darst, Correctional Officer; and (7) M. Knedler, Associate Warden. Plaintiff’s allegations involve a Rules Violation Report (“RVR”) he received after a riot on February 11, 2022 and the subsequent disciplinary hearing, the finding that plaintiff committed battery with a deadly weapon, and the imposition of punishment. Plaintiff complains of the following conduct by each defendant: • Sergeant Smith “weaponized” another inmate to disseminate false information which caused the riot. • Lieutenant Watkins refused to permit plaintiff to introduce exculpatory audio and video evidence during the May 21, 2022 disciplinary hearing; and failed to consider other exculpatory evidence, including the statement plaintiff made. Plaintiff further alleges Watkins conducted the disciplinary hearing in this manner to protect defendant Smith. • Plaintiff appears to allege that he gave CO Darst, the first investigative officer for the hearing, a written statement, requested the presence of employee Miller at the hearing, and showed Darst his grievance regarding audio and video evidence. That information does not appear in the disciplinary hearing results. Therefore, according to plaintiff, the hearing officer did not consider it. //// • Plaintiff appears to allege that the second investigative office, CO Acosta, either failed to correctly repeat the statement plaintiff provided for the disciplinary hearing record or that Acosta did repeat it but the record did not reflect that statement. • Plaintiff appears to allege that he requested a further statement from CO Miller to ask him why his three statements differed from the RVR he authored and whether he in fact authored the RVR. In can be inferred that plaintiff was unable to get that additional statement from Miller. Plaintiff further appears to be alleging that someone else wrote the RVR and he was unable to question that person during the hearing. • Associate Warden Knedler failed to properly review the results of the disciplinary hearing which violated Penal Code §2932. • Warden St. Andre failed to train Watkins and Knedler in the disciplinary process. Plaintiff concludes that these violations of his rights resulted in the disciplinary guilty finding and the imposition of a 365-day loss of behavior credits and an 18-month term in the Security Housing Unit (“SHU”). Plaintiff seeks compensatory and punitive damages and dismissal of the disciplinary conviction. III. Does Plaintiff State a Claim under § 1983? Plaintiff appears to be asserting four legal claims. First, he contends that defendant Smith caused false information to be disseminated, which resulted in the riot. Second, plaintiff alleges actions of defendants Watkins, Darst, and Acosta violated his rights to due process in the disciplinary process. Third, plaintiff alleges defendant Knedler failed to comply with state law regarding the review of disciplinary hearing results. Fourth, plaintiff alleges defendant St. Andre failed to properly train defendants Watkins and Knedler in disciplinary procedures. A. False Information Plaintiff was found guilty of battery with a deadly weapon. Plaintiff does not explain how defendant Smith’s alleged actions resulted in plaintiff’s guilty finding. Plaintiff either did, or did not, commit battery with a deadly weapon. Even if plaintiff could show Smith caused the riot, it does not follow that plaintiff did not commit battery. Plaintiff fails to connect the alleged actions //// of Smith with the harm he complains of. Accordingly, plaintiff’s claim against Smith will be dismissed with leave to amend. B. Conduct of Disciplinary Proceedings 1. Legal Standards Prisoners retain their right to due process subject to the restrictions imposed by the nature of the penal system. See Wolff v. McDonnell, 418 U.S. 539, 556 (1974). Prison disciplinary proceedings are not part of a criminal prosecution and the full panoply of rights due a defendant in such proceedings does not apply. See id. But the Due Process Clause requires certain minimum procedural protections where serious rules violations are alleged, the power of prison officials to impose sanctions is narrowly restricted by state statute or regulations, and the sanctions are severe. See id. at 556–57, 571–72 n.19. Wolff established five constitutionally mandated procedural requirements for disciplinary proceedings. First, “written notice of the charges must be given to the disciplinary-action defendant in order to inform him of the charges and to enable him to marshal the facts and prepare a defense.” Id. at 564. Second, “at least a brief period of time after the notice, no less than 24 hours, should be allowed to the inmate to prepare for the appearance before the [disciplinary committee].” Id. Third, “there must be a ‘written statement by the factfinders as to the evidence relied on and reasons’ for the disciplinary action.” Id. (quoting Morrissey v. Brewer, 408 U.S. 471, 489 (1972)). Fourth, “the inmate facing disciplinary proceedings should be allowed to call witnesses and present documentary evidence in his defense when permitting him to do so will not be unduly hazardous to institutional safety or correctional goals.” Id. at 566. And fifth, “[w]here an illiterate inmate is involved [or] the complexity of the issue makes it

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