Sanchez Martinez v. Freitas

CourtDistrict Court, N.D. California
DecidedJune 17, 2024
Docket4:23-cv-02508
StatusUnknown

This text of Sanchez Martinez v. Freitas (Sanchez Martinez v. Freitas) 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
Sanchez Martinez v. Freitas, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JULIO CESAR SANCHEZ MARTINEZ, Case No. 23-cv-02508-HSG

8 Plaintiff, ORDER DENYING LEAVE TO FILE AMENDED COMPLAINT; DENYING 9 v. AS MOOT REQUEST FOR EXTENSION OF TIME AND REQUEST TO STRIKE; 10 FREITAS, et al., ORDERING PLAINTIFF TO FILE OPPOSITION TO MOTION TO 11 Defendants. DISMISS 12 Re: Dkt. Nos. 13, 19, 20

13 14 Plaintiff, an inmate at Santa Cruz County Jail, has filed a pro se action pursuant to 42 15 U.S.C. § 1983. This order addresses the following motions: Plaintiff’s motion for an extension of 16 time to file his amended complaint, Dkt. No. 13; Plaintiff’s motion for leave to file an amended 17 complaint, Dkt. No. 19; and Defendants’ motion to strike the amended complaint, Dkt. No. 20. 18 DISCUSSION 19 I. Procedural Background 20 On or about May 23, 2023, Plaintiff commenced this action by filing the complaint 21 docketed at Dkt. No. 1. Dkt. No. 1. 22 On September 27, 2023, the Court found that the complaint stated the following cognizable 23 claim for relief: Santa Cruz County Jail’s new mail policy requiring that inmates receive their mail 24 in electronic format has deprived Plaintiff of his personal property without due process of law, in 25 violation of the First Amendment. The Court dismissed with leave to amend the claim that the 26 new mail policy violated Plaintiff’s First Amendment right to send and receive mail because the 27 complaint that other inmates had been unable to access their mail because of lack of access to the 1 Plaintiff leave to amend his First Amendment claim to clarify how the receipt of mail in electronic 2 format had denied him his First Amendment right to receive mail. The Court ordered Plaintiff to 3 file an amended complaint by October 25, 2023, and informed him that the failure to comply with 4 this deadline would result in Dkt. No. 1 remaining the operative complaint. See generally Dkt. 5 No. 4. On October 23, 2023, the Court granted Plaintiff an extension of time to November 27, 6 2023, to file an amended complaint. Dkt. No. 8. On November 24, 2023, Plaintiff requested a 7 final extension of time to file an amended complaint, stating that he wished to add additional 8 claims and defendants, so that he could avoid excessive filings and prosecuting multiple actions 9 simultaneously. Dkt. No. 13. 10 On November 20, 2023, Defendants filed a motion to dismiss the complaint, arguing that 11 the complaint must be dismissed because it fails to plead that the mail policy is not rationally 12 related to any legitimate penological interest and because the mail policy satisfies all three relevant 13 Turner prongs as a matter of law. Dkt. No. 11. 14 II. Plaintiff’s Motion Requesting an Extension of Time to File Amended Complaint (Dkt. 15 No. 13) and Requesting Leave to File Amended Complaint (Dkt. No. 19), and Defendants’ Request to Strike (Dkt. No. 20) 16 17 The Court DENIES Plaintiff’s request for an extension of time to file an amended 18 complaint, Dkt. No. 13, because, as discussed below, Plaintiff’s proposed amended complaint, 19 docketed at Dkt. No. 19, fails to state any cognizable claim for relief. An amended complaint 20 supersedes the original, the latter being treated thereafter as non-existent. Ramirez v. Cty. Of San 21 Bernardino, 806 F.3d 1002, 1008 (9th Cir. 2015). Consequently, claims not included in an 22 amended complaint are no longer claims and defendants not named in an amended complaint are 23 no longer defendants. See Ferdik v. Bonzelet, 963 F.2d 1258, 1262 (9th Cir. 1992). Allowing 24 Dkt. No. 19 to serve as the amended complaint would result in the amended complaint 25 superseding the initial complaint; the initial complaint’s cognizable claim regarding the jail’s 26 electronic mail policy being waived; and the dismissal of Dkt. No. 19 with leave to amend. 27 Because Dkt. No. 19 fails to state a cognizable claim for relief, the Court will construe Dkt. No. 19 1 proposed amended complaint at Dkt. No. 19 because amendment would be futile. 2 Fed. R. Civ. P. 15(a) is to be applied liberally in favor of amendments and, in general, 3 leave shall be freely given when justice so requires. See Janicki Logging Co. v. Mateer, 42 F.3d 4 561, 566 (9th Cir. 1994). However, “a district court need not grant leave to amend where the 5 amendment: (1) prejudices the opposing party; (2) is sought in bad faith; (3) produces an undue 6 delay in litigation; or (4) is futile.” AmerisourceBergen Corp. v. Dialysist West, Inc., 465 F.3d 7 946, 951 (9th Cir. 2006). 8 The proposed amended complaint docketed at Dkt. No. 19 fails to state any cognizable 9 claims for relief. Specifically, the proposed amended complaint suffers from the following 10 deficiencies. 11 First, the proposed amended complaint is simply a laundry list of jail policies and customs 12 that Plaintiff takes issue with. The proposed amended complaint does not identify any federal law 13 or constitutional provision that has been violated by the challenged jail policies or customs. 14 Second, the proposed amended complaint does not sufficiently link any of the named 15 defendants to the challenged jail policies or customs. While Fed. R. Civ. P. 8 does not require a 16 complaint to set forth detailed factual allegations, it demands more than an unadorned, the- 17 defendant-unlawfully-harmed-me accusation. Ashcroft v. Iqbal, 556 U.S. 662, 677–78 (2009). 18 The general statement that the named defendants “together are responsible for all current 19 conditions of [Plaintiff’s] confinement, . . . handle all grievances . . . have the last word when it 20 comes to every decisions (sic) made I have taken all my grievances to them . . . yet they all chosen 21 to ignore my pleas and continue to violate our rights with the way they do things” fails to 22 sufficiently link each named defendant to the challenged jail policies or customs. In Dkt. No. 1 23 (the initial complaint), Plaintiff challenged one policy – the mail policy – and alleged that he had 24 informed each of the named defendants of the problems caused by the mail policy. Liberally 25 construed, in this particular context, these allegations were sufficient to link the named defendants 26 to the alleged constitutional violation. In the proposed amended complaint, however, Plaintiff 27 challenges five jail policies, on vague and personal grounds, and then conclusorily states that the 1 do they handle all grievances but they have the last word when it comes to every decision made.” 2 Dkt. No. 19 at 9. In this particular context, Plaintiff appears to hold the named defendants 3 responsible for all jail conditions solely because of their supervisory position and their 4 participation in reviewing his grievances. Generally speaking, such allegations are insufficient to 5 state Section 1983 liability. There is no respondeat superior liability under § 1983, i.e., liability 6 solely because a defendant is a supervisor or otherwise responsible for the actions or omissions of 7 another. See Mortimer v. Baca, 594 F.3d 714, 721 (9th Cir. 2010); see also Jeffers v. Gomez, 267 8 F.3d 895, 915 (9th Cir.

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Sanchez Martinez v. Freitas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-martinez-v-freitas-cand-2024.