(PC) Ngo v. Campbell

District Court, E.D. California·Decided October 15, 2024·No. 1:23-cv-01423·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 MY NGO, Case No.: 1:23-cv-01423-KES-SKO 12 Plaintiff, FINDINGS AND RECOMMENDATIONS TO DISMISS PLAINTIFF’S FIRST AMENDED 13 v. COMPLAINT FOR A FAILURE TO STATE A CLAIM UPON WHICH RELIEF CAN BE 14 TAMMY CAMPBELL, et al., GRANTED 15 Defendants. (Doc. 12) 16 14-DAY OBJECTION PERIOD 17 18 Plaintiff My Ngo is proceeding pro se and in forma pauperis in this civil rights action 19 pursuant to 42 U.S.C. § 1983. 20 I. RELEVANT BACKGROUND 21 The Court issued its First Screening Order on January 2, 2024, (Doc. 9), and found 22 Plaintiff’s original complaint failed to state any claim upon which relief could be granted (Id. at 23 5-8.). Plaintiff was given leave to file a first amended complaint, curing the deficiencies 24 identified in the order, or to file a notice of voluntary dismissal, within 21 days. (Id. at 8-9.) On 25 February 5, 2024, Plaintiff filed a timely first amended complaint. (Doc. 12.) 26 II. SCREENING REQUIREMENT 27 The Court is required to screen complaints brought by prisoners seeking relief against a 1 The Court must dismiss a complaint or portion thereof if the complaint is frivolous or malicious, 2 fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant 3 who is immune from such relief. 28 U.S.C. § 1915A(b). The Court should dismiss a complaint if 4 it lacks a cognizable legal theory or fails to allege sufficient facts to support a cognizable legal 5 theory. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). 6 III. PLEADING REQUIREMENTS 7 A. Federal Rule of Civil Procedure 8(a) 8 “Rule 8(a)’s simplified pleading standard applies to all civil actions, with limited 9 exceptions.” Swierkiewicz v. Sorema N.A., 534 U.S. 506, 513 (2002). A complaint must contain 10 “a short and plain statement of the claims showing that the pleader is entitled to relief.” Fed. R. 11 Civ. P. 8(a)(2). “Such a statement must simply give the defendant fair notice of what the 12 plaintiff’s claim is and the grounds upon which it rests.” Swierkiewicz, 534 U.S. at 512 (internal 13 quotation marks & citation omitted). 14 Detailed factual allegations are not required, but “[t]hreadbare recitals of the elements of a 15 cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 16 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Plaintiff must 17 set forth “sufficient factual matter, accepted as true, to ‘state a claim that is plausible on its face.’” 18 Id. (quoting Twombly, 550 U.S. at 570). Factual allegations are accepted as true, but legal 19 conclusions are not. Id. (citing Twombly, 550 U.S. at 555). 20 The Court construes pleadings of pro se prisoners liberally and affords them the benefit of 21 any doubt. Hebbe v. Pliler, 627 F.3d 338, 342 (9th Cir. 2010) (citation omitted). However, “the 22 liberal pleading standard . . . applies only to a plaintiff’s factual allegations,” not his legal 23 theories. Neitzke v. Williams, 490 U.S. 319, 330 n.9 (1989). Furthermore, “a liberal interpretation 24 of a civil rights complaint may not supply essential elements of the claim that were not initially 25 pled,” Bruns v. Nat’l Credit Union Admin., 122 F.3d 1251, 1257 (9th Cir. 1997) (internal 26 quotation marks & citation omitted), and courts “are not required to indulge unwarranted 27 inferences.” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation 1 sufficient to state a cognizable claim, and “facts that are merely consistent with a defendant’s 2 liability” fall short. Iqbal, 556 U.S. at 678 (internal quotation marks & citation omitted). 3 B. Linkage and Causation 4 Section 1983 provides a cause of action for the violation of constitutional or other federal 5 rights by persons acting under color of state law. See 42 U.S.C. § 1983. To state a claim under 6 section 1983, a plaintiff must show a causal connection or link between the actions of the 7 defendants and the deprivation alleged to have been suffered by the plaintiff. See Rizzo v. Goode, 8 423 U.S. 362, 373-75 (1976). The Ninth Circuit has held that “[a] person ‘subjects’ another to the 9 deprivation of a constitutional right, within the meaning of section 1983, if he does an affirmative 10 act, participates in another’s affirmative acts, or omits to perform an act which he is legal required 11 to do that causes the deprivation of which complaint is made.” Johnson v. Duffy, 588 F.2d 740, 12 743 (9th Cir. 1978) (citation omitted). 13 C. Supervisory Liability 14 Liability may not be imposed on supervisory personnel for the actions or omissions of 15 their subordinates under the theory of respondeat superior. Iqbal, 556 U.S. at 676-77; see e.g., 16 Simmons v. Navajo Cty., Ariz., 609 F.3d 1011, 1020-21 (9th Cir. 2010) (plaintiff required to 17 adduce evidence the named supervisory defendants “themselves acted or failed to act 18 unconstitutionally, not merely that subordinate did”), overruled on other grounds by Castro v. 19 C’nty of Los Angeles, 833 F.3d 1060, 1070 (9th Cir. 2016); Jones v. Williams, 297 F.3d 930, 934 20 (9th Cir. 2002) (“In order for a person acting under color of state law to be liable under section 21 1983 there must be a showing of personal participation in the alleged rights deprivation: there is 22 no respondeat superior liability under section 1983”). 23 Supervisors may be held liable only if they “participated in or directed the violations, or 24 knew of the violations and failed to act to prevent them.” Taylor v. List, 880 F.2d 1040, 1045 (9th 25 Cir. 1989). “The requisite causal connection may be established when an official sets in motion a 26 ‘series of acts by others which the actor knows or reasonably should know would cause others to 27 inflict’ constitutional harms.” Corales v. Bennett, 567 F.3d 554, 570 (9th Cir. 2009). Accord 1 inaction in the training and supervision of subordinates). 2 Supervisory liability may also exist without any personal participation if the official 3 implemented “a policy so deficient that the policy itself is a repudiation of the constitutional 4 rights and is the moving force of the constitutional violation.” Redman v. Cty. of San Diego, 942 5 F.2d 1435, 1446 (9th Cir. 1991) (citations & quotations marks omitted), abrogated on other 6 grounds by Farmer v. Brennan, 511 U.S. 825 (1970). 7 To prove liability for an action or policy, the plaintiff “must ... demonstrate that his 8 deprivation resulted from an official policy or custom established by a ... policymaker possessed 9 with final authority to establish that policy.” Waggy v. Spokane County Washington, 594 F.3d 10 707, 713 (9th Cir.2010).

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