(PC) Wilson v. Siskiyou County Jail

CourtDistrict Court, E.D. California
DecidedApril 24, 2024
Docket2:23-cv-01358
StatusUnknown

This text of (PC) Wilson v. Siskiyou County Jail ((PC) Wilson v. Siskiyou County Jail) 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) Wilson v. Siskiyou County Jail, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 FOR THE EASTERN DISTRICT OF CALIFORNIA 11 12 DANIEL KEITH WILSON, No. 2:23-cv-01358 DAD-EFB (PC) 13 Plaintiff, 14 v. ORDER VACATING FINDINGS AND RECOMMENDATIONS 15 SISKIYOU COUNTY JAIL, 16 Defendant. 17 18 Plaintiff is a former prisoner proceeding without counsel. ECF No. 1. On July 19, 2023, 19 the postal service returned mail directed to plaintiff marked: “Undeliverable, No Longer Here.” 20 Because a party appearing without counsel must keep the court and all parties apprised of his or 21 her current address (E.D. Local Rule 183(b)), this court recommended dismissal of this action 22 without prejudice when plaintiff failed to notify the court of his current address within the 23 required time period. ECF No. 14. 24 Plaintiff has since updated the court with his current address and objected to the proposed 25 dismissal. ECF No. 15. Plaintiff has also moved for “zero time constraints and opportunity to 26 refile until I get it right.” Id. In addition, plaintiff moved for appointment of counsel and for in 27 forma pauperis (IFP) status before this matter was transferred to the Eastern District. ECF Nos. 8 28 and 9. Because plaintiff has now updated his address, this court withdraws its recommendation of 1 dismissal and proceeds to screening of plaintiff’s complaint. ECF No. 1. This court will also 2 address plaintiff’s other docketed motions. 3 Leave to Proceed In Forma Pauperis 4 Plaintiff, who no longer appears to be incarcerated, has filed an application to proceed 5 IFP in a non-prisoner case. ECF No. 8. Plaintiff’s application, however, is incomplete. For 6 example, plaintiff has not fully completed sections 1, 4, 8 or 10. Accordingly, plaintiff’s motion 7 for leave to proceed IFP is denied without prejudice. 8 Motion for Appointment of Counsel 9 District courts lack authority to require counsel to represent indigent plaintiffs in section 10 1983 cases. Mallard v. United States Dist. Court, 490 U.S. 296, 298 (1989). In exceptional 11 circumstances, the court may request an attorney to represent voluntarily such a plaintiff. See 28 12 U.S.C. § 1915(e)(1); Terrell v. Brewer, 935 F.2d 1015, 1017 (9th Cir. 1991); Wood v. 13 Housewright, 900 F.2d 1332, 1335-36 (9th Cir. 1990). When determining whether “exceptional 14 circumstances” exist, the court must consider the likelihood of success on the merits as well as the 15 ability of the plaintiff to articulate his claims pro se in light of the complexity of the legal issues 16 involved. Palmer v. Valdez, 560 F.3d 965, 970 (9th Cir. 2009). Having considered those factors, 17 the court finds there are no exceptional circumstances in this case. 18 Screening Standards 19 Federal courts must engage in a preliminary screening of cases in which prisoners seek 20 redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. 21 § 1915A(a). The court must identify cognizable claims or dismiss the complaint, or any portion 22 of the complaint, if the complaint “is frivolous, malicious, or fails to state a claim upon which 23 relief may be granted,” or “seeks monetary relief from a defendant who is immune from such 24 relief.” Id. at § 1915A(b). 25 A pro se plaintiff, like other litigants, must satisfy the pleading requirements of Rule 8(a) 26 of the Federal Rules of Civil Procedure. Rule 8(a)(2) “requires a complaint to include a short and 27 plain statement of the claim showing that the pleader is entitled to relief, in order to give the 28 defendant fair notice of what the claim is and the grounds upon which it rests.” Bell Atl. Corp. v. 1 Twombly, 550 U.S. 544, 554, 562-563 (2007) (citing Conley v. Gibson, 355 U.S. 41 (1957)). 2 While the complaint must comply with the “short and plain statement” requirements of Rule 8, its 3 allegations must also include the specificity required by Twombly and Ashcroft v. Iqbal, 556 U.S. 4 662, 679 (2009). 5 To avoid dismissal for failure to state a claim, a complaint must contain more than “naked 6 assertions,” “labels and conclusions” or “a formulaic recitation of the elements of a cause of 7 action.” Twombly, 550 U.S. at 555-557. In other words, “[t]hreadbare recitals of the elements of 8 a cause of action, supported by mere conclusory statements do not suffice.” Iqbal, 556 U.S. at 9 678. 10 Furthermore, a claim upon which the court can grant relief must have facial plausibility. 11 Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual 12 content that allows the court to draw the reasonable inference that the defendant is liable for the 13 misconduct alleged.” Iqbal, 556 U.S. at 678. When considering whether a complaint states a 14 claim upon which relief can be granted, the court must accept the allegations as true, Erickson v. 15 Pardus, 551 U.S. 89 (2007), and construe the complaint in the light most favorable to the 16 plaintiff. See Scheuer v. Rhodes, 416 U.S. 232, 236 (1974). 17 Screening Order 18 Plaintiff’s complaint, which is captioned “Medical Malpractice,” is presented as a two- 19 page letter to the court and is not filed on the form typically used in filing a complaint under the 20 Civil Rights Act, 42 U.S.C. § 1983. ECF No. 1. His complaint alleges that, due to staff neglect, 21 he contracted a staph infection in his foot while in Siskiyou County Jail. Id. at p. 2. Plaintiff 22 further alleges that also due to staff neglect, his infection spread, and was eventually diagnosed as 23 MRSA. Id. Among other relief, plaintiff demands “that all staff and head medical lady be 24 prosecuted for harassment, medical malpractice for her. . . .” Id. 25 To state a claim under section 1983, a plaintiff must allege: (1) the violation of a federal 26 constitutional or statutory right; and (2) that the violation was committed by a person acting under 27 the color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988); Jones v. Williams, 297 F. 3d 28 930, 934 (9th Cir. 2002). An individual defendant is not liable on a civil rights claim unless the 1 facts establish the defendant’s personal involvement in the constitutional deprivation or a causal 2 connection between the defendant’s wrongful conduct and the alleged constitutional deprivation. 3 See Hansen v. Black, 885 F. 2d 642, 646 (9th Cir. 1989). 4 Here, plaintiff does not identify any individual defendant, and instead names “Siskiyou 5 County Jail” as the sole defendant. While “[m]unicipalities and other local governmental units . . 6 . [are] among those persons to whom § 1983 applies,” Monell v. Dep’t of Soc. Servs., 436 U.S.

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(PC) Wilson v. Siskiyou County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-wilson-v-siskiyou-county-jail-caed-2024.