(PC) Sanchez v. Doe

District Court, E.D. California·Decided May 13, 2025·No. 2:24-cv-01681·Unknown

Opinion

JUAN CARLOS SANCHEZ, No. 2:24-cv-01681-EFB (PC) Plaintiff, v. ORDER FLOOR OFFICER JOHN DOE 1, et al., Defendants. Plaintiff is a state prisoner proceeding without counsel in an action brought under 42 U.S.C. § 1983. In addition to filing a complaint, he has filed an application to proceed in forma pauperis pursuant to 28 U.S.C. § 1915. The court will grant the in forma pauperis application and screen the complaint. Leave to Proceed In Forma Pauperis Plaintiff’s application makes the showing required by 28 U.S.C. § 1915(a)(1) and (2). Accordingly, by separate order, the court directs the agency having custody of plaintiff to collect and forward the appropriate monthly payments for the filing fee as set forth in 28 U.S.C. § 1915(b)(1) and (2). //// //// //// Screening Standards Federal courts must engage in a preliminary screening of cases in which prisoners seek redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The court must identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint “is frivolous, malicious, or fails to state a claim upon which relief may be granted,” or “seeks monetary relief from a defendant who is immune from such relief.” Id. § 1915A(b). A pro se plaintiff, like other litigants, must satisfy the pleading requirements of Rule 8(a) of the Federal Rules of Civil Procedure. Rule 8(a)(2) “requires a complaint to include a short and plain statement of the claim showing that the pleader is entitled to relief, in order to give the defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 554, 562-563 (2007) (citing Conley v. Gibson, 355 U.S. 41 (1957)). While the complaint must comply with the “short and plaint statement” requirements of Rule 8, its allegations must also include the specificity required by Twombly and Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). To avoid dismissal for failure to state a claim a complaint must contain more than “naked assertions,” “labels and conclusions” or “a formulaic recitation of the elements of a cause of action.” Twombly, 550 U.S. at 555-557. In other words, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements do not suffice.” Iqbal, 556 U.S. at 678. Furthermore, a claim upon which the court can grant relief must have facial plausibility. Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. When considering whether a complaint states a claim upon which relief can be granted, the court must accept the allegations as true, Erickson v. Pardus, 551 U.S. 89 (2007), and construe the complaint in the light most favorable to the plaintiff, see Scheuer v. Rhodes, 416 U.S. 232, 236 (1974). //// Screening Order Plaintiff alleges that, on September 3, 2023, he slipped on a puddle caused by a roof leak while housed at High Desert State Prison (“HDSP”). ECF No. 1 at 7. “Correctional officers” had known of the leak for a year but the roof had not been fixed, nor had any signs been placed warning of the hazard. Id. Plaintiff fell and suffered visible injuries. Id. He was taken to Banner Lassen Medical Center, but the nurses and doctor there refused to treat him. Id. at 8. They should have known that plaintiff, a person with adrenal insufficiency, does not take trauma well. Id. But they made plaintiff wait outside, gave him no test, and provided only a shot of Toradol before releasing plaintiff. Id. Plaintiff was ill for the following 20 days, when he was returned to the hospital with an adrenal crisis and hospitalized for a week. Id. He sues five unidentified correctional staff for violating his Eighth Amendment rights and committing gross negligence in connection with his fall and one unidentified doctor at Banner Lassen for violating his Eighth Amendment rights and discriminating against him in connection with his treatment. Plaintiff has not stated a cognizable Eighth Amendment claim against correctional staff at HDSP (John Doe Nos. 1-5). In the Ninth Circuit, slip-and-fall incidents in prisons generally fail to state cognizable constitutional claims. Julian v. Valley State Prison, No. 1:23-cv-00013-SAB (PC), 2023 U.S. Dist. LEXIS 85043, *5 (E.D. Cal. May 15, 2023). A slip-and-fall incident may give rise to a cognizable claim only if accompanied by exacerbating conditions—conditions that pose a serious, unavoidable threat to the plaintiff’s safety. Id. Thus, courts routinely dismiss slip- and-fall cases brought by prisoners as alleging mere negligence, even where defendants knew of and failed to remedy a hazardous condition on the floor. Collier v. Garcia, No. 17-CV-05841 LHK (PR), 2018 U.S. Dist. LEXIS 16909, at *3 (N.D. Cal. Jan. 31, 2018) (collecting cases). See generally, Murguia v. Langdon, 61 F.4th 1096, 1111 (9th Cir. 2023) (“Deliberate indifference is a stringent standard of fault, requiring proof that a municipal actor disregarded a known or obvious consequence of his action. This standard is higher than gross negligence and requires a culpable mental state.”) (internal citations and quotation marks omitted). Plaintiff has not alleged exacerbating conditions that would show deliberate indifference on the part of correctional staff, rather than gross negligence. Plaintiff has also failed to state a cognizable state-law negligence claim, because the complaint does not allege that plaintiff complied with California’s Tort Claims Act, which requires that any state tort claims against a public entity or its employees be presented to the state Victim Compensation and Government Claims Board within six months of the accrual of the cause of action. California v. Super. Ct. (Bodde), 32 Cal.4th 1234, 1245 (2004); Mangold v. Cal. Pub. Utils. Comm’n, 67 F.3d 1470, 1477 (9th Cir. 1995). Plaintiff’s claim for discrimination against his treating physician at Banner Lassen (John Doe No. 6) is also not cognizable as currently plead. The Fourteenth Amendment’s Equal Protection Clause is “essentially a direction that all persons similarly situated should be treated alike.” City of Cleburne, Tex. v. Cleburne Living Center, 473 U.S. 432, 439 (1985). To state an equal protection claim that is not based on membership in one of certain protected classes (e.g., race, sex), a plaintiff must allege that similarly situated individuals were intentionally treated differently without a rational basis for the difference in treatment. Village of Willowbrook v. Olech, 528 U.S. 562, 564 (2000). Such claims are often referred to as “class of one” equal protection claims. Engquist v. Oregon Dep'

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