(PC) Martinez v. Parks

CourtDistrict Court, E.D. California
DecidedDecember 18, 2024
Docket1:21-cv-01496
StatusUnknown

This text of (PC) Martinez v. Parks ((PC) Martinez v. Parks) 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) Martinez v. Parks, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 RONALD F. MARTINEZ, Case No.: 1:21-cv-001496-KES-CDB 12 Plaintiff, SECOND SCREENING ORDER

13 v.

14 A. PARKS, 15 Defendant. 16 17 Plaintiff Ronald F. Martinez is proceeding pro se and in forma pauperis in this civil rights 18 action pursuant to 42 U.S.C. section 1983. 19 I. INTRODUCTION 20 The Court issued its first screening order on August 2, 2023. (Doc. 44.) It found Plaintiff’s 21 operative complaint stated cognizable First Amendment retaliation claims against Defendants 22 Parks and M. Lirones based upon his litigation efforts but failed to state cognizable retaliation 23 claims based upon Plaintiff’s legal assistance to other inmates. (Id. at 12-13.) Plaintiff was given 24 leave to file a fourth amended complaint, or to file written notice that he did not want to amend 25 and wished to stand on his complaint as screened, or to file a notice of voluntary dismissal. (Id. at 26 13-14.) 27 On August 24, 2024, Plaintiff filed a fourth amended complaint. (Doc. 47.) 1 II. SCREENING REQUIREMENT 2 The Court is required to screen complaints brought by prisoners seeking relief against a 3 governmental entity or an officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). 4 The Court must dismiss a complaint or portion thereof if the complaint is frivolous or malicious, 5 fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant 6 who is immune from such relief. 28 U.S.C. § 1915A(b). The Court should dismiss a complaint if 7 it lacks a cognizable legal theory or fails to allege sufficient facts to support a cognizable legal 8 theory. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). 9 III. PLEADING REQUIREMENTS 10 A. Federal Rule of Civil Procedure 8(a) 11 “Rule 8(a)’s simplified pleading standard applies to all civil actions, with limited 12 exceptions.” Swierkiewicz v. Sorema N.A., 534 U.S. 506, 513 (2002). A complaint must contain 13 “a short and plain statement of the claims showing that the pleader is entitled to relief.” Fed. R. 14 Civ. P. 8(a)(2). “Such a statement must simply give the defendant fair notice of what the 15 plaintiff’s claim is and the grounds upon which it rests.” Swierkiewicz, 534 U.S. at 512 (internal 16 quotation marks & citation omitted). 17 Detailed factual allegations are not required, but “[t]hreadbare recitals of the elements of a 18 cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 19 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Plaintiff must 20 set forth “sufficient factual matter, accepted as true, to ‘state a claim that is plausible on its face.’” 21 Id. (quoting Twombly, 550 U.S. at 570). Factual allegations are accepted as true, but legal 22 conclusions are not. Id. (citing Twombly, 550 U.S. at 555). 23 The Court construes pleadings of pro se prisoners liberally and affords them the benefit of 24 any doubt. Hebbe v. Pliler, 627 F.3d 338, 342 (9th Cir. 2010) (citation omitted). However, “the 25 liberal pleading standard . . . applies only to a plaintiff’s factual allegations,” not his legal 26 theories. Neitzke v. Williams, 490 U.S. 319, 330 n.9 (1989). Furthermore, “a liberal interpretation 27 of a civil rights complaint may not supply essential elements of the claim that were not initially 1 quotation marks & citation omitted), and courts “are not required to indulge unwarranted 2 inferences.” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation 3 marks & citation omitted). The “sheer possibility that a defendant has acted unlawfully” is not 4 sufficient to state a cognizable claim, and “facts that are merely consistent with a defendant’s 5 liability” fall short. Iqbal, 556 U.S. at 678 (internal quotation marks & citation omitted). 6 B. Linkage and Causation 7 Section 1983 provides a cause of action for the violation of constitutional or other federal 8 rights by persons acting under color of state law. See 42 U.S.C. § 1983. To state a claim under 9 section 1983, a plaintiff must show a causal connection or link between the actions of the 10 defendants and the deprivation alleged to have been suffered by the plaintiff. See Rizzo v. Goode, 11 423 U.S. 362, 373-75 (1976). The Ninth Circuit has held that “[a] person ‘subjects’ another to the 12 deprivation of a constitutional right, within the meaning of section 1983, if he does an affirmative 13 act, participates in another’s affirmative acts, or omits to perform an act which he is legal required 14 to do that causes the deprivation of which complaint is made.” Johnson v. Duffy, 588 F.2d 740, 15 743 (9th Cir. 1978) (citation omitted). 16 C. Supervisory Liability 17 Liability may not be imposed on supervisory personnel for the actions or omissions of 18 their subordinates under the theory of respondeat superior. Iqbal, 556 U.S. at 676-77; see e.g., 19 Simmons v. Navajo Cty., Ariz., 609 F.3d 1011, 1020-21 (9th Cir. 2010) (plaintiff required to 20 adduce evidence the named supervisory defendants “themselves acted or failed to act 21 unconstitutionally, not merely that subordinate did”), overruled on other grounds by Castro v. 22 C’nty of Los Angeles, 833 F.3d 1060, 1070 (9th Cir. 2016); Jones v. Williams, 297 F.3d 930, 934 23 (9th Cir. 2002) (“In order for a person acting under color of state law to be liable under section 24 1983 there must be a showing of personal participation in the alleged rights deprivation: there is 25 no respondeat superior liability under section 1983”). 26 Supervisors may be held liable only if they “participated in or directed the violations, or 27 knew of the violations and failed to act to prevent them.” Taylor v. List, 880 F.2d 1040, 1045 (9th 1 ‘series of acts by others which the actor knows or reasonably should know would cause others to 2 inflict’ constitutional harms.” Corales v. Bennett, 567 F.3d 554, 570 (9th Cir. 2009). Accord 3 Starr v. Baca, 652 F.3d 1202, 1205-06 (9th Cir. 2011) (supervisory liability may be based on 4 inaction in the training and supervision of subordinates). 5 Supervisory liability may also exist without any personal participation if the official 6 implemented “a policy so deficient that the policy itself is a repudiation of the constitutional 7 rights and is the moving force of the constitutional violation.” Redman v. Cty. of San Diego, 942 8 F.2d 1435, 1446 (9th Cir. 1991) (citations & quotations marks omitted), abrogated on other 9 grounds by Farmer v.

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Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Swierkiewicz v. Sorema N. A.
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Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Simmons v. Navajo County, Ariz.
609 F.3d 1011 (Ninth Circuit, 2010)
Hebbe v. Pliler
627 F.3d 338 (Ninth Circuit, 2010)
Miller v. Hersman
594 F.3d 8 (D.C. Circuit, 2010)
Ivey v. Board of Regents of University of Alaska
673 F.2d 266 (Second Circuit, 1982)
Raymond Watison v. Mary Carter
668 F.3d 1108 (Ninth Circuit, 2012)
Rhodes v. Robinson
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Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Corales v. Bennett
567 F.3d 554 (Ninth Circuit, 2009)
Brodheim v. Cry
584 F.3d 1262 (Ninth Circuit, 2009)
Doe I v. Wal-Mart Stores, Inc.
572 F.3d 677 (Ninth Circuit, 2009)
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833 F.3d 1060 (Ninth Circuit, 2016)
Vignolo v. Miller
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