(PC) Mitchell v. St. Andre

CourtDistrict Court, E.D. California
DecidedOctober 1, 2024
Docket2:24-cv-01506
StatusUnknown

This text of (PC) Mitchell v. St. Andre ((PC) Mitchell v. St. Andre) 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) Mitchell v. St. Andre, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 COREY MITCHELL, No. 2:24-cv-1506 CKD P 12 Plaintiff, 13 v. ORDER 14 R. ST. ANDRE, et al., 15 Defendants. 16 17 Plaintiff is a state prisoner proceeding pro se and seeking relief pursuant to 42 U.S.C. § 18 1983 against employees of the California Department of Corrections and Rehabilitation (CDCR). 19 This proceeding was referred to this court by Local Rule 302 pursuant to 28 U.S.C. § 636(b)(1). 20 Plaintiff has paid the filing fee. 21 1. Screening 22 The court is required to screen complaints brought by prisoners seeking relief against a 23 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 24 court must dismiss a complaint or portion thereof if the prisoner has raised claims that are legally 25 “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek 26 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1),(2). 27 Plaintiff has filed three separate pleadings. Because the filing of an amended pleading 28 supersedes prior pleadings, see Loux v. Rhay, 375 F.2d 55, 57 (9th Cir. 1967), the court will 1 screen the latest pleading filed, plaintiff’s July 11, 2024, second amended complaint, and the two 2 prior pleadings will be dismissed. 3 Having reviewed plaintiff’s second amended complaint, the court finds that it fails to state 4 a claim upon which relief can be granted under federal law. Plaintiff’s second amended 5 complaint must also be dismissed. The court will, however, grant leave to file a third amended 6 complaint. 7 In his first claim, plaintiff asserts he has been subjected to cruel and unusual punishment 8 in violation of the Eighth Amendment. A violation of the Eighth Amendment occurs if an inmate 9 suffers injury as a result of a correctional official’s deliberate indifference to a substantial risk of 10 serious physical harm. Farmer v. Brennan, 511 U.S. 825, 834 (1994). In his second amended 11 complaint, plaintiff does not allege he was ever subjected to a substantial risk of serious physical 12 harm nor that he suffered any injury as a result of cruel and unusual punishment. Plaintiff’s 13 allegations mostly concern the manner in which prisoner disciplinary proceedings were carried 14 out. 15 In claim 2, plaintiff asserts his right to due process under the Fourteenth Amendment was 16 violated during prisoner disciplinary proceedings. When prisoner disciplinary proceedings result 17 in the revocation of good conduct sentence credit, certain procedures are required under the 18 Fourteenth Amendment which include: 19 1. Advance notice of the charges; 20 2. An opportunity to present a defense; 21 3. A written statement by the factfinder of the evidence relied upon and the reasons for 22 action taken; and 23 4. That the decision by the factfinder be supported by some evidence in the record. 24 Superintendent v. Hill, 472 U.S. 445, 454 (1985). 25 Because plaintiff does not assert that he ever received a revocation of sentence credit, he 26 has not adequately pled the denial of due process. In one instance, plaintiff alleges that a 27 disciplinary finding resulted in his being denied parole. Apparently, plaintiff was found guilty of 28 misuse of state food. Plaintiff asserts that this resulted in plaintiff being denied parole for three 1 years. There are two problems with this claim. First, plaintiff does not adequately explain how 2 this one disciplinary proceeding resulted in plaintiff being denied parole as the Board of Parole 3 Hearings considers numerous factors in determining whether to deny parole. In California, parole 4 decisions “shall” be based on “all relevant, reliable information” available to the Board, Cal. 5 Code Regs. tit. 15, § 2281(b). See id. (specifying multiple factors panel may consider). See also 6 Nettles v. Grounds, 830 F.3d 922, 935 (9th Cir. 2016) (noting that under California parole 7 regulations, “the presence of a disciplinary infraction does not compel the denial of parole, nor 8 does an absence of an infraction compel the grant of parole”). Plaintiff fails to point to anything 9 which reasonably suggests that he was denied parole because of the disciplinary findings 10 challenged. Second, plaintiff appears to admit that he took milk from the dining hall in violation 11 of regulations suggesting that even if plaintiff had been entitled to due process protections with 12 respect to the challenged disciplinary proceedings, there was at least “some evidence” to support 13 the finding. 14 With respect to claim 3, plaintiff asserts a denial of the First Amendment. However, 15 plaintiff fails to point to anything indicating he was denied his right to free speech in any 16 actionable way, nor punished for protected conduct. Plaintiff alleges he has been retaliated 17 against by correctional officials. Prison officials generally cannot retaliate against inmates for 18 exercising First Amendment rights. Rizzo v. Dawson, 778 F.2d 527, 531 (9th Cir. 1985). 19 Because a prisoner’s First Amendment rights are necessarily curtailed, however, a successful 20 retaliation claim requires a finding that “the prison authorities’ retaliatory action did not advance 21 legitimate goals of the correctional institution or was not tailored narrowly enough to achieve 22 such goals.” Id. at 532. The plaintiff bears the burden of pleading and proving the absence of 23 legitimate correctional goals for the conduct of which he complains. Pratt v. Rowland, 65 F.3d 24 802, 806 (9th Cir. 1995). Also, to state a claim for retaliation, plaintiff must point to facts 25 indicating a causal connection between the adverse action and the protected conduct. Watison v. 26 Carter, 668 F.3d 1108, 1114 (9th Cir. 2012). As pled, plaintiff does point to facts suggesting 27 adverse action was taken against him for protected conduct. 28 Plaintiff also complains about being threatened by certain defendants. Plaintiff is informed 1 that mere threats do not amount to an actionable Eighth Amendment claim. See Somers v. 2 Thurman, 109 F.3d 614, 622 (9th Cir. 1997) (“the exchange of verbal insults between inmates and 3 guards is a constant, daily ritual observed in this nation's prisons” of which “we do not approve,” 4 but which do not violate the Eighth Amendment); Gaut v. Sunn, 810 F.2d 923, 925 (9th Cir. 5 1987) (per curiam) (it “trivializes the Eighth Amendment to believe a threat constitutes a 6 constitutional wrong.”). 7 Additionally, plaintiff complains about the manner in which a prisoner grievance was 8 handled. Plaintiff is informed that prisoners do not have “a separate constitutional entitlement to 9 a specific prison grievance procedure.” Ramirez v. Galaza, 334 F.3d 850

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Related

Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Richard E. Loux v. B. J. Rhay, Warden
375 F.2d 55 (Ninth Circuit, 1967)
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)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Damous Nettles v. Randy Grounds
830 F.3d 922 (Ninth Circuit, 2016)
Somers v. Thurman
109 F.3d 614 (Ninth Circuit, 1997)
Ramirez v. Galaza
334 F.3d 850 (Ninth Circuit, 2003)
Ellis v. Cassidy
625 F.2d 227 (Ninth Circuit, 1980)
Rizzo v. Dawson
778 F.2d 527 (Ninth Circuit, 1985)

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Bluebook (online)
(PC) Mitchell v. St. Andre, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-mitchell-v-st-andre-caed-2024.