Ruffin v. San Francisco Sheriff's Department

CourtDistrict Court, N.D. California
DecidedMarch 5, 2021
Docket4:20-cv-07826
StatusUnknown

This text of Ruffin v. San Francisco Sheriff's Department (Ruffin v. San Francisco Sheriff's Department) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ruffin v. San Francisco Sheriff's Department, (N.D. Cal. 2021).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 SAN JOSE DIVISION 6 7 SHAWN RUFFIN, Case No. 20-cv-07826-VKD

8 Plaintiff, ORDER SCREENING COMPLAINT 9 v. PURSUANT TO 28 U.S.C. § 1915A; OF DISMISSAL WITH LEAVE TO 10 SAN FRANCISCO SHERIFF’S AMEND DEPARTMENT, et al., 11 Defendants.

12 13 Pro se plaintiff Shawn Ruffin, who appears to be a pretrial detainee at the “San Francisco 14 County Jail #3,” filed the instant civil rights action pursuant to 42 U.S.C. § 1983 against the San 15 Francisco Sheriff’s Department and numerous employees thereof. Dkt. No. 1 at 2. Mr. Ruffin has 16 consented to magistrate judge jurisdiction. Dkt. No. 7. The Court granted Mr. Ruffin’s motion for 17 leave to proceed in forma pauperis in a separate order. Dkt. No. 8. 18 I. STANDARD OF REVIEW 19 A federal court must conduct a preliminary screening in any case in which a prisoner seeks 20 redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 21 1915A(a). In its review, the Court must identify any cognizable claims and dismiss any claims 22 that are frivolous, malicious, fail to state a claim upon which relief may be granted, or seek 23 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1), (2). 24 Pro se pleadings must be liberally construed. Jackson v. Carey, 353 F.3d 750, 757 (9th Cir. 2003); 25 Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 26 To state a claim arising under federal law, it must be clear from the face of plaintiff’s well- 27 pleaded complaint that there is a federal question. Easton v. Crossland Mortg. Corp., 114 F.3d 1 an action under 42 U.S.C. § 1983, which “provides a cause of action for the ‘deprivation of any 2 rights, privileges, or immunities secured by the Constitution and laws’ of the United States.” 3 Wilder v. Virginia Hosp. Ass’n, 496 U.S. 498, 508 (1990) (quoting 42 U.S.C. § 1983). Section 4 1983 is not itself a source of substantive rights, but merely provides a method for vindicating 5 federal rights elsewhere conferred. Graham v. Connor, 490 U.S. 386, 393–94 (1989). 6 To state a claim for relief under § 1983, a plaintiff must allege two essential elements: (1) 7 that a right secured by the Constitution or laws of the United States was violated, and (2) that the 8 alleged violation was committed by a person acting under the color of state law. West v. Atkins, 9 487 U.S. 42, 48 (1988). 10 II. BACKGROUND 11 Mr. Ruffin alleges that on April 10, 2020, Deputy Truong and Senior Deputy James placed 12 him in a cell that was not up to “institution standards” as it was “filthy,” the sink was not working, 13 and it had just been sprayed for COVID-19 virus a few hours earlier. Dkt. No. 1 at 3. Mr. Ruffin 14 also alleges that on April 11, 2020, Deputy Orsha discriminated against him when Deputy Orsha 15 took away a phone from him when he asked for a spray bottle to clean it, and then proceeded to 16 give the phone to a “caucasian-white inmate” whom Mr. Ruffin asserts is a member of Deputy 17 Orsha’s “LGBTQ Community.” Id. Mr. Ruffin also alleges that Lt. Collins and Lt. Martindale 18 deprived him of a shower for five days, from August 10, 2020 to August 15, 2020. Id. Mr. Ruffin 19 names numerous other individuals as defendants, claiming that there is a total of “105 to 110” total 20 deputy officers involved, but makes no specific allegations against them in his statement of claim. 21 Id. at 2. Mr. Ruffin seeks “criminal prosecution” against the deputies as well as damages. Id. at 3. 22 III. DISCUSSION 23 A. Conditions of Pretrial Detention 24 When a pretrial detainee challenges conditions of his confinement, the proper inquiry is 25 whether the conditions amount to punishment in violation of the Due Process Clause of the 26 Fourteenth Amendment. Bell v. Wolfish, 441 U.S. 520, 535 n.16 (1979). Accordingly, as a 27 pretrial detainee, Mr. Ruffin’s allegations regarding unsanitary cell conditions and the deprivation 1 The state may detain a pretrial detainee “to ensure his presence at trial and may subject him 2 to the restrictions and conditions of the detention facility so long as those conditions and 3 restrictions do not amount to punishment or otherwise violate the Constitution.” Id. at 536–37. If 4 a particular condition or restriction of pretrial detention is reasonably related to a legitimate 5 governmental objective it does not, without more, amount to punishment. Id. at 539. Because 6 states must be able to take steps to maintain security and order at pretrial facilities, restrictions and 7 conditions that are reasonably related to a facility’s interest in maintaining jail security and order 8 are not, without more, unconstitutional punishment. Id. at 540. 9 To determine whether a particular condition or restriction of pretrial detention amounts to 10 punishment in the constitutional sense of the word, the Court first looks to whether the disability 11 imposed is for the purpose of punishment or whether it is but an incident of some other legitimate 12 governmental purpose. Id. at 538. Absent a showing of an express intent to punish, whether a 13 condition or restriction amounts to punishment generally will turn on whether there is an 14 alternative, rational purpose for the condition/restriction, and whether the condition/restriction 15 appears excessive in relation to that alternative purpose. Id.; Demery v. Arpaio, 378 F.3d 1020, 16 1028 (9th Cir. 2004). If a restriction or condition is not reasonably related to a legitimate goal, 17 i.e., if it is arbitrary or purposeless, a court may infer that the purpose of the governmental action 18 is punishment. Bell, 441 U.S. at 539; see, e.g., Demery, 378 F.3d at 1029–33 (upholding 19 injunction against webcams that streamed live images of pretrial detainees to Internet users around 20 world because webcam transmissions harmed detainees by publicly humiliating them and were not 21 an incident of a legitimate governmental purpose). 22 The allegations in the complaint are insufficient to state a Fourteenth Amendment claim. 23 Mr. Ruffin claims that he was placed in a “filthy” cell with a broken sink, and that the cell had just 24 been sprayed for COVID-19. Dkt. No. 1 at 3. It is not clear whether Mr. Ruffin contends that the 25 cell was “filthy” because of the broken sink and the COVID-19 spray, or whether he contends that 26 these separate conditions collectively amount to impermissible punishment. In any event, Mr.

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

Related

Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Wilder v. Virginia Hospital Assn.
496 U.S. 498 (Supreme Court, 1990)
Winston Holloway v. Robert Gunnell, Warden, Fci
685 F.2d 150 (Fifth Circuit, 1982)
Michael Henry Ferdik v. Joe Bonzelet, Sheriff
963 F.2d 1258 (Ninth Circuit, 1992)
More v. Farrier
984 F.2d 269 (Eighth Circuit, 1993)
Anderson v. County of Kern
45 F.3d 1310 (Ninth Circuit, 1995)
Demery v. Arpaio
378 F.3d 1020 (Ninth Circuit, 2004)
Edward Furnace v. Paul Sullivan
705 F.3d 1021 (Ninth Circuit, 2013)
Taylor v. Riojas
592 U.S. 7 (Supreme Court, 2020)
Carnell v. Grimm
74 F.3d 977 (Ninth Circuit, 1996)
Timm v. Gunter
917 F.2d 1093 (Eighth Circuit, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
Ruffin v. San Francisco Sheriff's Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ruffin-v-san-francisco-sheriffs-department-cand-2021.