Richardson v. Whatcom County Jail

CourtDistrict Court, W.D. Washington
DecidedMay 15, 2025
Docket2:25-cv-00206
StatusUnknown

This text of Richardson v. Whatcom County Jail (Richardson v. Whatcom County Jail) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richardson v. Whatcom County Jail, (W.D. Wash. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 PRESTON EUGENE RICHARDSON, Case No. 2:25-cv-00206-DGE-TLF 7 Plaintiff, v. ORDER TO SHOW CAUSE 8 WHATCOM COUNTY JAIL, et al. 9 Defendants. 10

11 Plaintiff Preston Eugene Richardson, proceeding pro se and in forma pauperis 12 (IFP), filed this civil rights complaint under 42 U.S.C. 1983. Dkt. 15. Plaintiff, a pretrial 13 detainee at the time he filed his IFP application seeks damages and injunctive relief 14 from Defendants Whatcom County Jail, Erikson, Lovell, Hindman, Tjoeker, and 15 John/Jane Doe. Dkt. 15-2, Complaint (2-19-2025), at 1-4, Dkt. 15-3, Dkt. 15-4.1 Plaintiff 16 sued the defendants in their individual and official capacities. Id. at 1. Having reviewed 17 and screened the Complaint under 28 U.S.C. §1915A, the Court declines to serve the 18 Complaint but provides plaintiff leave to file an amended pleading by June 6, 2025, to 19 cure the deficiencies identified in this Order to Show Cause. 20 I. DISCUSSION 21

22 1 Plaintiff filed his original complaint on January 27, 2025. Dkt. 1. Because he did not properly file the application to proceed IFP, the Court did not process that complaint. Dkt. 5, 12. Plaintiff requested to 23 amend his complaint. Dkt. 9, 15-4. Plaintiff filed an amended complaint, and properly submitted his application for IFP on April 14, 2025. Dkt. 15. That complaint is the operative complaint analyzed in this 24 Order to Show Cause. Dkt. 15-2. 1 Under the Prison Litigation Reform Act of 1995, the Court is required to screen 2 complaints brought by prisoners seeking relief against a governmental entity or officer 3 or employee of a governmental entity. 28 U.S.C. § 1915A(a). The Court must “dismiss 4 the complaint, or any portion of the complaint, if the complaint: (1) is frivolous,

5 malicious, or fails to state a claim upon which relief may be granted; or (2) seeks 6 monetary relief from a defendant who is immune from such relief.” Id. at (b); 28 U.S.C. § 7 1915(e)(2); see Barren v. Harrington, 152 F.3d 1193 (9th Cir. 1998). 8 The Court is required to liberally construe pro se documents. Estelle v. Gamble, 9 429 U.S. 97, 106 (1976). Even so, Federal Rule of Civil Procedure 8 requires a 10 complaint to contain “a short and plain statement of the claim showing that the pleader 11 is entitled to relief.” Fed. R. Civ. P. 8(a). “Each allegation must be simple, concise, and 12 direct.” Fed. R. Civ. P. 8(d). 13 Plaintiff’s complaint is more than 90 pages, he also includes a letter explaining 14 some of the claims, and he filed 268 pages of attachments, which he incorporates by

15 reference into the complaint. Dkt. 15-2, 15-3, 15-4. Many pages in plaintiff’s complaint 16 are illegible because the scanned image is faint and unreadable. See, e.g., Shuster v. 17 Oppelman, 962 F. Supp. 394, 396 (S.D.N.Y. 1997) (holding that a partially illegible pro 18 se complaint does not comply with Rule 8); Knutson v. Lucky Store, Inc., No. CIV S-07- 19 0981-LKK-EFB-P, 2008 U.S. Dist. LEXIS 116353, 2008 WL 4167076, at *1 (E.D. Cal. 20 Sept. 5, 2008) (dismissing a pro se complaint that was mostly illegible and did not 21 comply with Rule 8). Plaintiff should use dark ink and ensure the copies are legible in 22 future pleadings. 23 Further, in order to state a claim for relief under 42 U.S.C. § 1983, a plaintiff must

24 1 show that (1) he suffered a violation of rights protected by the Constitution or created by 2 federal statute and (2) the violation was proximately caused by a person acting under 3 color of state law. See Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). 4 Additionally, a plaintiff must allege facts showing how a defendant caused or personally

5 participated in causing the harm alleged in the complaint. Leer v. Murphy, 844 F.2d 628, 6 633 (9th Cir. 1988); Arnold v. IBM, 637 F.2d 1350, 1355 (9th Cir.1981). To avoid 7 dismissal for failure to state a claim, plaintiff must include more than sweeping 8 conclusory allegations against an official. Leer, 844 F.2d at 633. A claim upon which 9 the Court can grant relief must have facial plausibility, which requires plaintiff to plead 10 more than the “sheer possibility that a defendant has acted unlawfully.” Ashcroft v. 11 Iqbal, 556 U.S. 662, 678 (2009). 12 The readable portion of the Complaint shows plaintiff is alleging that the 13 individual defendants violated his constitutional rights by subjecting him to solitary 14 confinement after receiving “false allegations” under the Prison Rape Elimination Act

15 and denying him the opportunity to be removed from solitary confinement. Plaintiff 16 names several defendants, but based on the readable portion of the Complaint, it does 17 not appear plaintiff alleged each defendant’s personal action(s) or inaction(s) that 18 resulted in plaintiff’s continued isolation. It appears he is making a claim that the 19 defendants deprived him of procedural and substantive due process, and equal 20 protection of law, under the Fifth and Fourteenth Amendments. Dkt. 15-2. In his motion 21 to amend, plaintiff requests to add more claims and defendants. Dkt 15-4. 22 Plaintiff does not provide sufficient context or factual details to “nudge[] [his] 23 claims across the line from conceivable to plausible.” Bell Atlantic Corp. v. Twombly,

24 1 550 U.S. 544, 547 (2007); see also Iqbal, 556 U.S. at 680. Accordingly, plaintiff does 2 not state his claims in a manner that plausibly alleges the personal participation of each 3 defendant, in individual or official capacity. Although plaintiff refers to potentially 4 cognizable claims, those claims are not actionable against defendants, in their individual

5 or official capacity, without additional factual allegations establishing how each 6 defendant allegedly violated plaintiff’s constitutional rights. Also, plaintiff has submitted a 7 letter, a motion to amend, and numerous exhibits to the complaint. 8 Plaintiff names Whatcom County Jail as a defendant. The Jail is not a proper 9 defendant in a Section 1983 lawsuit. 42 U.S.C. § 1983 applies to the actions of 10 “persons” acting under color of state law. This definition includes municipalities, such as 11 counties. Monell v. New York City Dept.

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Related

Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Michael Lacey v. Joseph Arpaio
693 F.3d 896 (Ninth Circuit, 2012)
Shuster v. Oppelman
962 F. Supp. 394 (S.D. New York, 1997)
Forsyth v. Humana, Inc.
114 F.3d 1467 (Ninth Circuit, 1997)

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Richardson v. Whatcom County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richardson-v-whatcom-county-jail-wawd-2025.