Smith v. Alameda County Sheriff Dept

CourtDistrict Court, N.D. California
DecidedNovember 17, 2023
Docket3:22-cv-07200
StatusUnknown

This text of Smith v. Alameda County Sheriff Dept (Smith v. Alameda County Sheriff Dept) 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
Smith v. Alameda County Sheriff Dept, (N.D. Cal. 2023).

Opinion

1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 NORTHERN DISTRICT OF CALIFORNIA 8 9 D’ANDRE SMITH, Case No. 22-cv-07200-AMO (PR)

10 Plaintiff, ORDER OF DISMISSAL WITH LEAVE TO AMEND 11 v.

12 ALAMEDA COUNTY SHERIFF DEPT., et al., 13 Defendants. 14 15

16 I. INTRODUCTION 17 Plaintiff D’Andre Smith, who is currently in custody at North Kern State Prison, filed a 18 pro se civil rights action pursuant to 42 U.S.C. § 1983, alleging constitutional violations at Santa 19 Rita Jail (“SRJ”) where he was previously incarcerated. This suit was reassigned from a 20 magistrate judge to the undersigned in light of Ninth Circuit authority.1 Smith also seeks leave to 21 proceed in forma pauperis, which will be granted in a separate Order. 22 Venue is proper in this judicial district because the events giving rise to the claim are 23 alleged to have occurred at SRJ, which is located herein. See 28 U.S.C. § 1391(b). Smith names 24 the following defendants: “Alameda County Sheriff’s Dept.” and “Valley Care Hospital[,] Dublin, 25 26 1 Williams v. King, 875 F.3d 500, 503 (9th Cir. 2017) (concluding that magistrate judge 27 lacked jurisdiction to dismiss case on initial screening because unserved defendants had not 1 [California].” Dkt. 1 at 2.2 Smith seeks monetary damages. Id. at 7. 2 II. DISCUSSION 3 A. Standard of Review 4 A federal court must conduct a preliminary screening in any case in which a prisoner seeks 5 redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. 6 § 1915A(a). In its review, the Court must identify any cognizable claims and dismiss any claims 7 that are frivolous, malicious, fail to state a claim upon which relief may be granted or seek 8 monetary relief from a defendant who is immune from such relief. Id. § 1915A(b)(1), (2). Pro se 9 pleadings must be liberally construed. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th 10 Cir. 1988). 11 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential elements: 12 (1) that a right secured by the Constitution or laws of the United States was violated, and (2) that 13 the alleged violation was committed by a person acting under the color of state law. West v. 14 Atkins, 487 U.S. 42, 48 (1988). 15 Liability may be imposed on an individual defendant under section 1983 if the plaintiff can 16 show that the defendant proximately caused the deprivation of a federally protected right. Leer v. 17 Murphy, 844 F.2d 628, 634 (9th Cir. 1988); Harris v. City of Roseburg, 664 F.2d 1121, 1125 (9th 18 Cir. 1981). A person deprives another of a constitutional right within the meaning of section 1983 19 if he does an affirmative act, participates in another’s affirmative act or fails to perform an act 20 which he is legally required to do, that causes the deprivation of which the plaintiff complains. 21 Leer, 844 F.2d at 633; see, e.g., Robins v. Meecham, 60 F.3d 1436, 1442 (9th Cir. 1995) (finding 22 that a prison official’s failure to intervene to prevent Eighth Amendment violation may be basis 23 for liability). The inquiry into causation must be individualized and focus on the duties and 24 responsibilities of each individual defendant whose acts or omissions are alleged to have caused a 25 constitutional deprivation. Leer, 844 F.2d at 633. 26 A supervisor may be liable under section 1983 upon a showing of (1) personal 27 1 involvement in the constitutional deprivation or (2) a sufficient causal connection between the 2 supervisor’s wrongful conduct and the constitutional violation. Redman v. County of San Diego, 3 942 F.2d 1435, 1446 (9th Cir. 1991) (en banc) (citation omitted). A supervisor therefore generally 4 “is only liable for constitutional violations of his subordinates if the supervisor participated in or 5 directed the violations, or knew of the violations and failed to act to prevent them.” Taylor v. List, 6 880 F.2d 1040, 1045 (9th Cir. 1989). “‘Supervisory liability is imposed against a supervisory 7 official in his individual capacity for his own culpable action or inaction in the training, 8 supervision, or control of his subordinates, for his acquiescence in the constitutional deprivations 9 of which the complaint is made, or for conduct that showed a reckless or callous indifference to 10 the rights of others.’” Preschooler II v. Davis, 479 F.3d 1175, 1183 (9th Cir. 2007) (citations 11 omitted). Evidence of a prisoner’s letter to an administrator alerting him to a constitutional 12 violation is sufficient to generate a genuine issue of material fact as to whether the administrator 13 was aware of the violation, even if he denies knowledge and there is no evidence the letter was 14 received. Jett, 439 F.3d at 1098. Evidence that a prison supervisor was personally involved in an 15 unconstitutional transfer and denied all appeals of the transfer, for example, may suffice. 16 Hamilton v. Endell, 981 F.2d 1062, 1067 (9th Cir. 1992); see also Watkins v. City of Oakland, 145 17 F.3d 1087, 1093 (9th Cir. 1998) (finding that a supervisor who signed an internal affairs report 18 dismissing complaint against officer despite evidence of officer’s use of excessive force may be 19 liable for damages). 20 B. Analysis 21 Rule 8(a) of the Federal Rules of Civil Procedure requires that a complaint set forth “a 22 short and plain statement of the claim showing that the pleader is entitled to relief.” Additionally, 23 Rule 8(e) requires that each averment of a pleading be “simple, concise, and direct.” See 24 McHenry v. Renne, 84 F.3d 1172, 1179 (9th Cir. 1996) (affirming dismissal of complaint that was 25 “argumentative, prolix, replete with redundancy, and largely irrelevant”). While the federal rules 26 require brevity in pleading, a complaint nevertheless must be sufficient to give the defendants “fair 27 notice” of the claim and the “grounds upon which it rests.” Erickson v. Pardus, 127 S. Ct. 2197, 1 the defendant that violated the plaintiff’s rights fails to meet the notice requirements of Rule 8(a). 2 See Hutchinson v. United States, 677 F.2d 1322, 1328 n.5 (9th Cir. 1982). Moreover, under 3 section 1983, liability may be imposed on an individual defendant only if the plaintiff can show 4 that the defendant proximately caused the deprivation of a federally protected right. See Leer, 844 5 F.2d at 634. As explained above, a supervisor may be liable under section 1983 only upon a 6 showing of (1) personal involvement in the constitutional deprivation or (2) a sufficient causal 7 connection between the supervisor’s wrongful conduct and the constitutional violation.

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