(PC) Magana v. County of Kern

CourtDistrict Court, E.D. California
DecidedJanuary 2, 2025
Docket1:23-cv-00561
StatusUnknown

This text of (PC) Magana v. County of Kern ((PC) Magana v. County of Kern) 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) Magana v. County of Kern, (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 STEVEN MAGANA, No. 1:23-cv-00561 GSA (PC) 12 Plaintiff, SCREENING ORDER 13 v. ORDER DIRECTING PLAINTIFF TO FILE AMENDED COMPLAINT 14 COUNTY OF KERN, et al., PLAINTIFF’S AMENDED COMPLAINT 15 Defendants. DUE IN THIRTY DAYS 16 17 Plaintiff, a county jail inmate proceeding pro se and in forma pauperis, has filed this civil 18 rights action seeking relief under 42 U.S.C. § 1983. The matter was referred to a United States 19 Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1)(B) and Local Rule 302. 20 For the reasons stated below, Plaintiff will be ordered to file an amended complaint. He 21 will be given thirty days to do so. 22 I. SCREENING REQUIREMENT 23 The Court is required to screen complaints brought by prisoners seeking relief against a 24 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 25 Court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 26 “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek 27 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1)-(2). 28 “Notwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall 1 dismiss the case at any time if the court determines that the action or appeal fails to state a claim 2 upon which relief may be granted.” 28 U.S.C. § 1915(e)(2)(B)(ii). 3 A complaint is required to contain “a short and plain statement of the claim showing that 4 the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not 5 required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere 6 conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell 7 Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). While a plaintiff’s allegations are taken 8 as true, courts “are not required to indulge unwarranted inferences.” Doe I v. Wal-Mart Stores, 9 Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation marks and citation omitted). To state a 10 viable claim, Plaintiff must set forth “sufficient factual matter, accepted as true, to ‘state a claim 11 to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678-79; Moss v. United States Secret 12 Service, 572 F.3d 962, 969 (9th Cir. 2009). While factual allegations are accepted as true, legal 13 conclusions are not. Id. The mere possibility of misconduct falls short of meeting this 14 plausibility standard. Id. 15 Finally, under Federal Rules of Civil Procedure 18 and 20, the claims raised against a 16 party in a complaint should be related. In addition, defendants should only be joined in an action 17 if it can be alleged that they are liable for the “same transaction, occurrence, or series of 18 transactions or occurrences” where “any question of law or fact common to all defendants will 19 arise in the action.” See Fed. R. Civ. P. 18(a) and 20(a)(2). 20 II. STANDARD OF REVIEW 21 A. Generally 22 Section 1983 “provides a cause of action for the deprivation of any rights, privileges, or 23 immunities secured by the Constitution and laws of the United States.” Wilder v. Virginia Hosp. 24 Ass’n, 496 U.S. 498, 508 (1990) (quoting 42 U.S.C. § 1983). Section 1983 is not itself a source 25 of substantive rights, but merely provides a method for vindicating federal rights conferred 26 elsewhere. Graham v. Connor, 490 U.S. 386, 393-94 (1989). 27 To state a claim under Section 1983, a plaintiff must allege two essential elements: (1) 28 that a right secured by the Constitution or laws of the United States was violated and (2) that the 1 alleged violation was committed by a person acting under the color of state law. See West v. 2 Atkins, 487 U.S. 42, 48 (1988); Ketchum v. Alameda Cty., 811 F.2d 1243, 1245 (9th Cir. 1987). 3 B. Linkage Requirement 4 In addition, under Section 1983, a plaintiff bringing an individual capacity claim must 5 demonstrate that each defendant personally participated in the deprivation of his rights. See Jones 6 v. Williams, 297 F.3d 930, 934 (9th Cir. 2002). There must be an actual connection or link 7 between the actions of the defendants and the deprivation alleged to have been suffered by 8 plaintiff. See Ortez v. Washington County, State of Oregon, 88 F.3d 804, 809 (9th Cir. 1996); 9 see also Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989). 10 Government officials may not be held liable for the actions of their subordinates under a 11 theory of respondeat superior. Iqbal, 556 U.S. at 676 (stating vicarious liability is inapplicable in 12 Section 1983 suits). Since a government official cannot be held liable under a theory of vicarious 13 liability in Section 1983 actions, a plaintiff must plead sufficient facts showing that the official 14 has violated the Constitution through his own individual actions by linking each named defendant 15 with some affirmative act or omission that demonstrates a violation of plaintiff's federal rights. 16 Iqbal, 556 U.S. at 676. 17 III. PLAINTIFF’S COMPLAINT 18 Plaintiff is an inmate who is currently incarcerated at Kern County Lerdo Detention 19 Facility. ECF No. 1 at 1. In his complaint, he names three defendants: (1) Kern County; (2) 20 Delano Police Department, and (3) the City of Delano. Id. at 1-2. 21 A. Claims and Harm Alleged 22 Plaintiff appears to attempt to raise two claims in the complaint: (1) the use of excessive 23 force in violation of his rights under the Fourteenth Amendment and the “Discrimination Act,” 24 and (2) the denial of basic necessities related to his mental health in violation of the Fourth 25 Amendment. ECF No. 1 at 3-4. In Claim One, Plaintiff generally states – in relevant part – that 26 since the age of sixteen, he has struggled with mental stability. Id. at 3. He further states that he 27 has always been “institutionalized” six to nine months out of a year in county jail. Id. He asserts 28 that he “feel[s] hated on and also feel[s] discriminated on.” Id. (brackets added).

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