(PS) Sanders v. Sacramento Sheriff's Department

CourtDistrict Court, E.D. California
DecidedSeptember 1, 2022
Docket2:22-cv-01232
StatusUnknown

This text of (PS) Sanders v. Sacramento Sheriff's Department ((PS) Sanders v. Sacramento Sheriff's Department) 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
(PS) Sanders v. Sacramento Sheriff's Department, (E.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 SASSUS SANDERS, No. 2:22-cv-01232-TLN-CKD PS 12 Plaintiff, 13 v. ORDER 14 SACRAMENTO SHERIFF’S 15 DEPARTMENT, et al., 16 Defendants. 17 18 Plaintiff’s proceeds without counsel and seeks relief under 42 U.S.C. § 1983.1 Plaintiff’s 19 complaint filed on July 13, 2022 (ECF No. 1) is before the court for screening. Plaintiff has also 20 filed an application in support of a request to proceed in forma pauperis. The application makes 21 the showing required by 28 U.S.C. § 1915. (ECF No. 2.) Accordingly, the motion to proceed in 22 forma pauperis will be granted. 23 For the reasons set forth below, the allegations of the complaint, as currently pleaded, fail 24 to state a cognizable claim. Plaintiff will have an opportunity to file an amended complaint. In 25 any amended complaint, plaintiff shall allege in specific terms how each named defendant is 26 involved in the alleged violations. 27 1 This matter was referred to the undersigned pursuant to Local Rule 302(c)(21). See 28 U.S.C. § 28 636(b)(1). 1 I. SCREENING REQUIREMENT 2 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 3 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a 4 claim on which relief may be granted,” or “seeks monetary relief against a defendant who is 5 immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 6 (2000). A claim is legally frivolous when it lacks an arguable basis either in law or in fact. 7 Neitzke v. Williams, 490 U.S. 319, 325 (1989). In reviewing a complaint under this standard, the 8 court accepts as true the factual allegations contained in the complaint, unless they are clearly 9 baseless or fanciful, and construes those allegations in the light most favorable to the plaintiff. 10 See Neitzke, 490 U.S. at 327; Von Saher v. Norton Simon Museum of Art at Pasadena, 592 F.3d 11 954, 960 (9th Cir. 2010), cert. denied, 564 U.S. 1037 (2011). 12 Pro se pleadings are held to a less stringent standard than those drafted by lawyers. Haines 13 v. Kerner, 404 U.S. 519, 520 (1972). However, the court need not accept as true conclusory 14 allegations, unreasonable inferences, or unwarranted deductions of fact. Western Mining Council 15 v. Watt, 643 F.2d 618, 624 (9th Cir. 1981). A formulaic recitation of the elements of a cause of 16 action does not suffice to state a claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555-57 17 (2007); Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). 18 To state a claim on which relief may be granted, the plaintiff must allege enough facts “to 19 state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has facial 20 plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable 21 inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. A pro se 22 litigant is entitled to notice of the deficiencies in the complaint and an opportunity to amend 23 unless the complaint’s deficiencies could not be cured by amendment. See Noll v. Carlson, 809 24 F.2d 1446, 1448 (9th Cir. 1987), superseded on other grounds by statute as stated in Lopez v. 25 Smith, 203 F.3d 1122 (9th Cir. 2000) (en banc). 26 II. PLAINTIFF’S ALLEGATIONS 27 Plaintiff was previously in custody at the Sacramento County Main Jail and seeks 28 monetary damages for violations of his civil rights that allegedly took place there. (See generally, 1 ECF No. 1.) Plaintiff has a traumatic brain injury and describes himself as mentally incompetent 2 with unstable cognitive thinking. (Id. at 3.) 3 While plaintiff was in custody at the jail, he had difficulty sending and receiving mail, 4 including legal mail. Plaintiff did not receive replies to some letters he sent out. Other mail was 5 received late because it was held by floor facilitators. Some mail was never received at all. (See 6 ECF No. 1 at 3-4.) 7 While plaintiff was in custody, various requests he made at the jail would take a long time 8 to receive responses or would not be responded to at all. As a result of his medical kites being 9 ignored, plaintiff did not receive medical care for his injured hand. Plaintiff also needed 10 medication from Wal-mart but was denied this medication. (See ECF No. 1 at 4, 6, 5, 8.) 11 On one occasion plaintiff was left in his cell without water for three days. During this 12 time, he had to use the restroom without being able to flush feces and urine from the toilet. (See 13 ECF No. 1 at 8.) 14 On an unspecified date, plaintiff had a physical dispute with another inmate. Plaintiff was 15 moved to a different portion of the facility and held there for three days even though the other 16 inmate was the aggressor. During this time, plaintiff was denied opportunities to call his attorney. 17 Due to this incident, as well as the issues with the mail, plaintiff was unable to communicate with 18 his attorney and with his family about his proper release date, which resulted in the loss of a 19 section 8 voucher, among other harm. (See ECF No. 1 at 4, 8.) 20 III. THE COMPLAINT FAILS TO STATE A CLAIM 21 A. Lack of Factual Allegations Specific to the Named Defendants 22 The complaint does not describe the conduct that the named defendants engaged in that 23 violated plaintiff’s rights. Because the named defendants are not actually mentioned in plaintiff’s 24 factual allegations, the court is unable to discern what facts underlie the causes of action plaintiff 25 is attempting to bring, and against whom. 26 Although the Federal Rules adopt a flexible pleading policy, even a pro se litigant’s 27 complaint must give fair notice and state the elements of a claim plainly and succinctly. Jones v. 28 Community Redev. Agency, 733 F.2d 646, 649 (9th Cir. 1984); Fed. R. Civ. P. 8(a)(2) (requiring 1 a short and plain statement of the claim). The complaint must be dismissed because it does not 2 contain sufficient factual content to allow the court to draw the reasonable inference that any 3 named defendant has violated plaintiff’s constitutional rights. 4 B. Legal Standards under the Civil Rights Act (42 U.S.C. § 1983) 5 To state a claim under the Civil Rights Act, 42 U.S.C. § 1983, a plaintiff must allege two 6 essential elements: (1) that a right secured by the Constitution or laws of the United States was 7 violated, and (2) that the alleged violation was committed by a person acting under the color of 8 state law. West v. Atkins, 487 U.S. 42, 48 (1988).

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Bluebook (online)
(PS) Sanders v. Sacramento Sheriff's Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-sanders-v-sacramento-sheriffs-department-caed-2022.