(PC) McClung v. CA Board of State and Community Corrections

CourtDistrict Court, E.D. California
DecidedJune 9, 2025
Docket2:22-cv-01740
StatusUnknown

This text of (PC) McClung v. CA Board of State and Community Corrections ((PC) McClung v. CA Board of State and Community Corrections) 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) McClung v. CA Board of State and Community Corrections, (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 BRADLEY JAMES McCLUNG, No. 2:22-cv-01740 TLN SCR P 12 Plaintiff, 13 v. ORDER 14 CALIFORNIA BOARD OF STATE AND COMMUNITY CORRECTIONS, et al., 15 Defendants. 16 17 18 Plaintiff is a state inmate proceeding pro se and in forma pauperis with a civil rights action 19 under 42 U.S.C. § 1983. Before the undersigned is plaintiff’s third amended complaint (“TAC”) 20 for screening (ECF No. 30) and request for reasonable accommodations (ECF No. 32). 21 For the reasons set forth below, the undersigned finds that the TAC states a cognizable 22 Fourteenth Amendment claim regarding the amount of daily in-cell confinement against 23 defendant Placer County and defendants Powers and Bell in their official capacities, but no other 24 cognizable claims. Further, plaintiff’s request for reasonable accommodations is denied without 25 prejudice. 26 LEGAL STANDARDS 27 I. Statutory Screening of Prisoner Complaints 28 The court is required to screen complaints brought by prisoners seeking relief against “a 1 governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A(a). In 2 performing this screening function, the court must dismiss any claim that “(1) is frivolous, 3 malicious, or fails to state a claim upon which relief may be granted; or (2) seeks monetary relief 4 from a defendant who is immune from such relief.” Id. § 1915A(b). A claim is legally frivolous 5 when it lacks an arguable basis either in law or in fact. Neitzke v. Williams, 490 U.S. 319, 325 6 (1989). The court may dismiss a claim as frivolous if it is based on an indisputably meritless 7 legal theory or factual contentions that are baseless. Neitzke, 490 U.S. at 327. The critical 8 inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable legal and 9 factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989). 10 In order to avoid dismissal for failure to state a claim a complaint must contain more than 11 “naked assertions,” “labels and conclusions” or “a formulaic recitation of the elements of a cause 12 of action.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-557 (2007). In other words, 13 “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory 14 statements do not suffice.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A claim upon which the 15 court can grant relief has facial plausibility. Twombly, 550 U.S. at 570. “A claim has facial 16 plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable 17 inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. When 18 considering whether a complaint states a claim, the court must accept the allegations as true, 19 Erickson v. Pardus, 551 U.S. 89, 93-94 (2007), and construe the complaint in the light most 20 favorable to the plaintiff, Scheuer v. Rhodes, 416 U.S. 232, 236 (1974). 21 II. 42 U.S.C. § 1983 22 A plaintiff may bring an action under 42 U.S.C. § 1983 to redress violations of “rights, 23 privileges, or immunities secured by the Constitution and [federal] laws” by a person or entity, 24 including a municipality, acting under the color of state law. 42 U.S.C. § 1983. To state a claim 25 under 42 U.S.C. § 1983, a plaintiff must show that (1) a defendant acting under color of state law 26 (2) deprived plaintiff of rights secured by the Constitution or federal statutes. Benavidez v. 27 County of San Diego, 993 F.3d 1134, 1144 (9th Cir. 2021). 28 //// 1 III. Monell Liability 2 Municipalities cannot be held vicariously liable under § 1983 for the actions of their 3 employees. Monell v. Dep’t of Social Services, 436 U.S. 585 at 691, 694 (1978). “Instead, it is 4 when execution of a government’s policy or custom, whether made by its lawmakers or by those 5 whose edicts or acts may fairly be said to represent official policy, inflicts the injury that the 6 government as an entity is responsible under § 1983.” Id. at 694. Municipalities are considered 7 “persons” under 42 U.S.C. § 1983 and therefore may be liable for causing a constitutional 8 deprivation. Monell, 436 U.S. 658, 690 (1978); Long v. County of Los Angeles, 442 F.3d 1178, 9 1185 (9th Cir. 2006). 10 To properly plead a Monell claim based on an unconstitutional custom, practice, or policy, 11 plaintiff must show that the government “had a deliberate policy, custom, or practice that was the 12 moving force behind the constitutional violation [plaintiff] suffered.” AE ex rel. Hernandez v. 13 County of Tulare, 666 F.3d 631, 636 (9th Cir. 2012) (quotation marks and citation omitted). 14 Plaintiff must also show that the policy or custom of the government “reflects deliberate 15 indifference” to plaintiff’s constitutional rights. Castro v. County of Los Angeles, 833 F.3d 1060, 16 1073 (9th Cir. 2016) (quotation marks and citation omitted). Unless the challenged policy is in 17 writing, the municipal policy at issue must be the result of a “‘longstanding practice or custom 18 which constitutes the standard operating procedure of the local government entity.’” Price v. 19 Sery, 513 F.3d 962, 966 (9th Cir. 2008) (quoting Ulrich v. City & Cnty. of San Francisco, 308 20 F.3d 968, 984-85 (9th Cir. 2002) (quotation omitted). 21 IV. Linkage 22 Section 1983 requires that there be an actual connection or link between the actions of the 23 defendants and the deprivation alleged to have been suffered by plaintiff. See Monell, 436 U.S. 24 at 694; Rizzo v. Goode, 423 U.S. 362, 370-71 (1976). Plaintiff may demonstrate that connection 25 by alleging facts showing: (1) a defendant's “personal involvement in the constitutional 26 deprivation,” or (2) that a defendant set “in motion a series of acts by others” or “knowingly 27 refus[ed] to terminate a series of acts by others, which [the defendant] knew or reasonably should 28 have known would cause others to inflict a constitutional injury.” Starr v. Baca, 652 F.3d 1202, 1 1207-08 (9th Cir. 2011) (quotation marks and citation omitted). 2 PLAINTIFF’S TAC 3 I. Factual Allegations 4 The TAC’s claims concern the conditions of confinement at the South Placer Jail (“SPJ”) 5 and Placer County Jail (“PCJ”). Plaintiff was booked into the custody and care of SPJ on May 8, 6 2022, and transferred to PCJ on October 20, 2022. (ECF No.

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Related

Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Robertson v. Wegmann
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Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Swierkiewicz v. Sorema N. A.
534 U.S. 506 (Supreme Court, 2002)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
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375 F.2d 55 (Ninth Circuit, 1967)
Johnson v. Duffy
588 F.2d 740 (Ninth Circuit, 1978)
Ivey v. Board of Regents of University of Alaska
673 F.2d 266 (Second Circuit, 1982)
AE Ex Rel. Hernandez v. County of Tulare
666 F.3d 631 (Ninth Circuit, 2012)
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Bluebook (online)
(PC) McClung v. CA Board of State and Community Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-mcclung-v-ca-board-of-state-and-community-corrections-caed-2025.