(PC) Valencia v. C.D.C.R.

CourtDistrict Court, E.D. California
DecidedOctober 9, 2024
Docket1:23-cv-00831
StatusUnknown

This text of (PC) Valencia v. C.D.C.R. ((PC) Valencia v. C.D.C.R.) 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) Valencia v. C.D.C.R., (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 CHRISTOPHER G. VALENCIA, Case No.: 1:23-cv-000831-SKO 12 Plaintiff, FINDINGS AND RECOMMENDATIONS TO DISMISS CERTAIN CLAIMS AND 13 v. DEFENDANTS FOLLOWING SCREENING

14 C.D.C.R., et al., (Doc. 7)

15 Defendants. 14-DAY OBJECTION PERIOD

16 Clerk of the Court to Assign District Judge

17 Plaintiff Christopher G. Valencia is proceeding pro se in this civil rights action pursuant to 18 42 U.S.C. § 1983. 19 I. INTRODUCTION 20 The Court issued its First Screening Order on January 3, 2024. (Doc. 6.) The Court 21 determined Plaintiff had failed to state a claim upon which relief could be granted, (Id. at 4-15), 22 and granted Plaintiff leave to file a first amended complaint. (Id. at 15-16.) On January 22, 2024, 23 Plaintiff filed a first amended complaint. (Doc. 7.) 24 II. SCREENING REQUIREMENT 25 The Court is required to screen complaints brought by prisoners seeking relief against a 26 governmental entity or an officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). 27 The Court must dismiss a complaint or portion thereof if the complaint is frivolous or malicious, 1 fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant 2 who is immune from such relief. 28 U.S.C. § 1915A(b). The Court should dismiss a complaint if 3 it lacks a cognizable legal theory or fails to allege sufficient facts to support a cognizable legal 4 theory. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1990). 5 III. PLEADING REQUIREMENTS 6 A. Federal Rule of Civil Procedure 8(a) 7 “Rule 8(a)’s simplified pleading standard applies to all civil actions, with limited 8 exceptions.” Swierkiewicz v. Sorema N.A., 534 U.S. 506, 513 (2002). A complaint must contain 9 “a short and plain statement of the claims showing that the pleader is entitled to relief.” Fed. R. 10 Civ. P. 8(a)(2). “Such a statement must simply give the defendant fair notice of what the 11 plaintiff’s claim is and the grounds upon which it rests.” Swierkiewicz, 534 U.S. at 512 (internal 12 quotation marks & citation omitted). 13 Detailed factual allegations are not required, but “[t]hreadbare recitals of the elements of a 14 cause of action, supported by mere conclusory statements, do not suffice.” Ashcroft v. Iqbal, 556 15 U.S. 662, 678 (2009) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). Plaintiff must 16 set forth “sufficient factual matter, accepted as true, to ‘state a claim that is plausible on its face.’” 17 Id. (quoting Twombly, 550 U.S. at 570). Factual allegations are accepted as true, but legal 18 conclusions are not. Id. (citing Twombly, 550 U.S. at 555). 19 The Court construes pleadings of pro se prisoners liberally and affords them the benefit of 20 any doubt. Hebbe v. Pliler, 627 F.3d 338, 342 (9th Cir. 2010) (citation omitted). However, “the 21 liberal pleading standard . . . applies only to a plaintiff’s factual allegations,” not his legal 22 theories. Neitzke v. Williams, 490 U.S. 319, 330 n.9 (1989). Furthermore, “a liberal interpretation 23 of a civil rights complaint may not supply essential elements of the claim that were not initially 24 pled,” Bruns v. Nat’l Credit Union Admin., 122 F.3d 1251, 1257 (9th Cir. 1997) (internal 25 quotation marks & citation omitted), and courts “are not required to indulge unwarranted 26 inferences.” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation 27 marks & citation omitted). The “sheer possibility that a defendant has acted unlawfully” is not 1 liability” fall short. Iqbal, 556 U.S. at 678 (internal quotation marks & citation omitted). 2 B. Linkage and Causation 3 Section 1983 provides a cause of action for the violation of constitutional or other federal 4 rights by persons acting under color of state law. See 42 U.S.C. § 1983. To state a claim under 5 section 1983, a plaintiff must show a causal connection or link between the actions of the 6 defendants and the deprivation alleged to have been suffered by the plaintiff. See Rizzo v. Goode, 7 423 U.S. 362, 373-75 (1976). The Ninth Circuit has held that “[a] person ‘subjects’ another to the 8 deprivation of a constitutional right, within the meaning of section 1983, if he does an affirmative 9 act, participates in another’s affirmative acts, or omits to perform an act which he is legal required 10 to do that causes the deprivation of which complaint is made.” Johnson v. Duffy, 588 F.2d 740, 11 743 (9th Cir. 1978) (citation omitted). 12 C. Supervisory Liability 13 Liability may not be imposed on supervisory personnel for the actions or omissions of 14 their subordinates under the theory of respondeat superior. Iqbal, 556 U.S. at 676-77; see e.g., 15 Simmons v. Navajo Cty., Ariz., 609 F.3d 1011, 1020-21 (9th Cir. 2010) (plaintiff required to 16 adduce evidence the named supervisory defendants “themselves acted or failed to act 17 unconstitutionally, not merely that subordinate did”), overruled on other grounds by Castro v. 18 C’nty of Los Angeles, 833 F.3d 1060, 1070 (9th Cir. 2016); Jones v. Williams, 297 F.3d 930, 934 19 (9th Cir. 2002) (“In order for a person acting under color of state law to be liable under section 20 1983 there must be a showing of personal participation in the alleged rights deprivation: there is 21 no respondeat superior liability under section 1983”). 22 Supervisors may be held liable only if they “participated in or directed the violations, or 23 knew of the violations and failed to act to prevent them.” Taylor v. List, 880 F.2d 1040, 1045 (9th 24 Cir. 1989). “The requisite causal connection may be established when an official sets in motion a 25 ‘series of acts by others which the actor knows or reasonably should know would cause others to 26 inflict’ constitutional harms.” Corales v. Bennett, 567 F.3d 554, 570 (9th Cir. 2009). Accord Starr 27 v. Baca, 652 F.3d 1202, 1205-06 (9th Cir. 2011) (supervisory liability may be based on inaction 1 Supervisory liability may also exist without any personal participation if the official 2 implemented “a policy so deficient that the policy itself is a repudiation of the constitutional 3 rights and is the moving force of the constitutional violation.” Redman v. Cty. of San Diego, 942 4 F.2d 1435, 1446 (9th Cir. 1991) (citations & quotations marks omitted), abrogated on other 5 grounds by Farmer v. Brennan, 511 U.S. 825 (1994). 6 To prove liability for an action or policy, the plaintiff “must ... demonstrate that his 7 deprivation resulted from an official policy or custom established by a ... policymaker possessed 8 with final authority to establish that policy.” Waggy v. Spokane County Washington, 594 F.3d 9 707, 713 (9th Cir.2010).

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(PC) Valencia v. C.D.C.R., Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-valencia-v-cdcr-caed-2024.