(PC)Witkin v. Snelling

CourtDistrict Court, E.D. California
DecidedMarch 13, 2024
Docket2:21-cv-02181
StatusUnknown

This text of (PC)Witkin v. Snelling ((PC)Witkin v. Snelling) 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)Witkin v. Snelling, (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 MICHAEL AARON WITKIN, No. 2:21-cv-02181 DAD AC 12 Plaintiff, 13 v. ORDER 14 C. SNELLING, et al., 15 Defendants. 16 17 Plaintiff is a former state prisoner proceeding pro se and in forma pauperis in this civil 18 rights action filed pursuant to 42 U.S.C. § 1983. Plaintiff’s first amended complaint is before the 19 court for screening. ECF No. 19. 20 I. Statutory Screening of Prisoner Complaints 21 As plaintiff was previously advised, the court is required to screen complaints brought by 22 prisoners seeking relief against “a governmental entity or officer or employee of a governmental 23 entity.” 28 U.S.C. § 1915A(a). The court must dismiss a complaint or portion thereof if the 24 prisoner has raised claims that are “frivolous, malicious, or fail[] to state a claim upon which 25 relief may be granted,” or that “seek[] monetary relief from a defendant who is immune from 26 such relief.” 28 U.S.C. § 1915A(b). 27 //// 28 //// 1 II. Amended Complaint 2 Plaintiff presents nine separate claims against fourteen named defendants and 50 unnamed 3 Doe defendants employed at California Medical Facility during various periods in 2021. 4 In his first claim, plaintiff alleges that on September 17, 2021, defendants Arrezola and 5 Damacion conducted a strip search that was unreasonable because it was performed next to a low 6 dose scanner that could have been used instead, and because defendants admitting knowing that 7 plaintiff did not have contraband. Defendant Benavidez reviewed the grievance that plaintiff 8 filed on October 15, 2021 concerning this search. 9 Claim Two contends that defendants Bennamon, Wheeler, and Conner retaliated against 10 plaintiff in violation of the First Amendment based on the issuance and administrative review of a 11 false rules violation report (“RVR”) that was meant to punish plaintiff for filing staff complaints 12 and lawsuits. Defendant Conner issued the RVR and defendants Bennamon and Wheeler 13 reviewed it after plaintiff filed a grievance. Plaintiff alleges that this RVR was retaliatory 14 because a counseling chrono could have been issued instead. 15 In Claim Three, plaintiff asserts a separate First Amendment retaliation claim against 16 defendants Conner, Sawyer, Bennamon, Wheeler, Gonzalez, and Kahie for placing him in 17 administrative segregation (“ASU”) as a “time out” for his litigious conduct. ECF No. 19 at 6. 18 Specifically, plaintiff alleges that defendant Sawyer ordered plaintiff to be placed in ASU after 19 defendants Bennamon, Wheeler, Gonzalez and Kahie told him that they wanted plaintiff moved 20 because he “had become too aggressive in asserting his legal rights.” ECF No. 19 at 6. 21 Defendant Conner escorted plaintiff from the visitation room to a holding cell before he was 22 placed in the ASU. 23 Claim Four asserts a Fourteenth Amendment violation by defendant Sawyer based on the 24 conditions of plaintiff’s confinement in ASU, on grounds that plaintiff suffered extreme sleep and 25 nutritional deprivation and was deprived of meaningful access to exercise. 26 In his fifth and sixth claims, plaintiff asserts a First Amendment retaliation and Fourteenth 27 Amendment due process claim against defendants Brodie and Martinez based on their 28 participation in a November 3, 2021 Institutional Classification Committee (“ICC”) hearing. 1 Plaintiff alleges they retaliated against him by denying him program credits because of his history 2 of filing lawsuits. They also denied him procedural due process by denying him written notice, 3 an opportunity to call witnesses and present evidence, and a written explanation of their decision. 4 Defendant Lacompte knowingly and unlawfully removed 150 days of plaintiff’s program credits 5 from the SOMS computer system. 6 Claim Seven and Eight assert a Fourteenth Amendment procedural due process and First 7 Amendment retaliation claim against defendant Pittsley, who presided over plaintiff’s November 8 13, 2021 disciplinary hearing. Specifically, plaintiff contends that Pittsley suppressed his 9 documentary evidence and ability to ask questions of witnesses based on his history of filing 10 lawsuits against correctional officers. 11 The last claim is a First Amendment retaliation claim against defendant Wheeler for 12 assigning plaintiff a cell mate that ended up injuring plaintiff due to plaintiff’s history of filing 13 grievances. 14 As to all of the individual retaliation claims, plaintiff asserts that his First Amendment 15 rights were chilled. With respect to Claims Six and Seven that are based on the loss of program 16 credits affecting his sentence, plaintiff asserts that these challenges are proper because has already 17 served the additional time that was forfeited. ECF No. 19 at 11-12. By way of relief, plaintiff 18 seeks all remedies provided by law. 19 III. Claims for Which a Response Will Be Required 20 After conducting the required screening, the court finds that plaintiff may proceed on the 21 Fourth Amendment unreasonable search claim against defendants Arrezola and Damacion (Claim 22 One); the First Amendment retaliation claims against defendants Sawyer, Bennamon, Wheeler, 23 Gonzalez, Kahie, Brodie, Martinez, and Pittsley (Claims Three, Five, Eight, Nine); and, the 24 Fourteenth Amendment procedural due process claim against defendant Pittsley (Claim Seven). 25 IV. Failure to State a Claim 26 There are no factual allegations involving defendants C. Snelling or Does 1-50 in the 27 amended complaint. For this reason alone, plaintiff fails to state a claim against these defendants. 28 The factual allegations against defendant Lacompte do not establish a constitutional violation 1 based on his removal of program credits from the SOMS computer system because plaintiff does 2 not allege that such conduct was based on any of plaintiff’s protected conduct. A viable claim of 3 First Amendment retaliation entails five basic elements: (1) An assertion that a state actor took 4 some adverse action against an inmate (2) because of (3) that prisoner's protected conduct, and 5 that such action (4) chilled the inmate's exercise of his First Amendment rights, and (5) the action 6 did not reasonably advance a legitimate correctional goal. Rhodes v. Robinson, 408 F.3d 559 7 567-68 (9th Cir. 2005) (citations omitted). Therefore, plaintiff does not state a retaliation claim 8 against defendant Lacompte as alleged in Claim Six. 9 Claim Two against defendant Conner fails to state a claim for the issuance and review of a 10 false RVR. See Sprouse v. Babcock, 870 F.2d 450, 452 (8th Cir. 1989) (stating that a prisoner 11 has no constitutionally-guaranteed immunity from being falsely or wrongly accused of conduct 12 that may lead to disciplinary sanctions). Plaintiff does not state a constitutional claim for relief 13 simply because plaintiff could have been issued a counseling chrono rather than an RVR. 14 Plaintiff additionally fails to state a claim against defendants Benavidez (Claim One), 15 Bennamon (Claim Two), and Wheeler (Claim Two) based on their review of his administrative 16 grievances. A prison official’s action in reviewing an inmate grievance cannot serve as a basis 17 for liability under Section 1983. Buckley v. Barlow, 997 F.2d 494, 495 (8th Cir. 1993).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Herring Gas Co., Inc. v. Magee
22 F.3d 603 (Fifth Circuit, 1994)
Jackson v. Indiana
406 U.S. 715 (Supreme Court, 1972)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Moody v. Daggett
429 U.S. 78 (Supreme Court, 1976)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Velázquez-Fernández v. NCE Foods, Inc.
476 F.3d 6 (First Circuit, 2007)
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)
Oscar W. Jones v. Lou Blanas County of Sacramento
393 F.3d 918 (Ninth Circuit, 2004)
Rhodes v. Robinson
408 F.3d 559 (Ninth Circuit, 2005)
Michael Lacey v. Joseph Arpaio
693 F.3d 896 (Ninth Circuit, 2012)
Johnson v. Lewis
217 F.3d 726 (Ninth Circuit, 2000)
Johnson v. Duffy
588 F.2d 740 (Ninth Circuit, 1978)
Buckley v. Barlow
997 F.2d 494 (Eighth Circuit, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
(PC)Witkin v. Snelling, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pcwitkin-v-snelling-caed-2024.