Tamrat v. Marlowe

CourtDistrict Court, N.D. California
DecidedJanuary 12, 2021
Docket4:20-cv-07623
StatusUnknown

This text of Tamrat v. Marlowe (Tamrat v. Marlowe) 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
Tamrat v. Marlowe, (N.D. Cal. 2021).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 HERMAN TAMRAT, Case No. 20-cv-07623-PJH

8 Plaintiff, ORDER OF DISMISSAL WITH LEAVE 9 v. TO AMEND

10 SONOMA COUNTY DETENTION FACILITY'S ADMINISTRATION, et al., 11 Defendants.

12 13 Plaintiff, a state prisoner, has filed a pro se civil rights complaint under 42 U.S.C. § 14 1983. He has been granted leave to proceed in forma pauperis. 15 DISCUSSION 16 STANDARD OF REVIEW 17 Federal courts must engage in a preliminary screening of cases in which prisoners 18 seek redress from a governmental entity or officer or employee of a governmental entity. 19 28 U.S.C. § 1915A(a). In its review the court must identify any cognizable claims, and 20 dismiss any claims which are frivolous, malicious, fail to state a claim upon which relief 21 may be granted, or seek monetary relief from a defendant who is immune from such 22 relief. Id. at 1915A(b)(1),(2). Pro se pleadings must be liberally construed. Balistreri v. 23 Pacifica Police Dep't, 901 F.2d 696, 699 (9th Cir. 1990). 24 Federal Rule of Civil Procedure 8(a)(2) requires only "a short and plain statement 25 of the claim showing that the pleader is entitled to relief." "Specific facts are not 26 necessary; the statement need only '"give the defendant fair notice of what the . . . . claim 27 is and the grounds upon which it rests."'" Erickson v. Pardus, 551 U.S. 89, 93 (2007) 1 factual allegations, . . . a plaintiff's obligation to provide the 'grounds’ of his 'entitle[ment] 2 to relief' requires more than labels and conclusions, and a formulaic recitation of the 3 elements of a cause of action will not do. . . . Factual allegations must be enough to 4 raise a right to relief above the speculative level." Bell Atlantic Corp. v. Twombly, 550 5 U.S. 544, 555 (2007) (citations omitted). A complaint must proffer "enough facts to state 6 a claim to relief that is plausible on its face." Id. at 570. The United States Supreme 7 Court has recently explained the “plausible on its face” standard of Twombly: “While legal 8 conclusions can provide the framework of a complaint, they must be supported by factual 9 allegations. When there are well-pleaded factual allegations, a court should assume their 10 veracity and then determine whether they plausibly give rise to an entitlement to relief.” 11 Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). 12 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 13 elements: (1) that a right secured by the Constitution or laws of the United States was 14 violated, and (2) that the alleged deprivation was committed by a person acting under the 15 color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). 16 LEGAL CLAIMS 17 Plaintiff presents many allegations of mistreatment while in custody including 18 excessive force, improper medical care and retaliation.1 19 The Due Process Clause of the Fourteenth Amendment protects a post- 20 arraignment pretrial detainee from the use of excessive force that amounts to 21 punishment. Graham v. Connor, 490 U.S. 386, 395 n.10 (1989) (citing Bell v. Wolfish, 22 441 U.S. 520, 535-39 (1979)). To prove an excessive force claim under § 1983, a pretrial 23 detainee must show only that the “force purposely or knowingly used against him was 24 objectively unreasonable.” Kingsley v. Hendrickson, 135 S. Ct. 2466, 2473 (2015). “A 25 court must make this determination from the perspective of a reasonable officer on the 26 scene, including what the officer knew at the time, not with the 20/20 vision of hindsight.” 27 1 Id. “A court (judge or jury) cannot apply this standard mechanically.” Id. “[O]bjective 2 reasonableness turns on the ‘facts and circumstances of each particular case.’” Id. 3 (quoting Graham v. Connor, 490 U.S. at 396). 4 A non-exhaustive list of considerations that may bear on the reasonableness of 5 the force used include “the relationship between the need for the use of force and the 6 amount of force used; the extent of the plaintiff's injury; any effort made by the officer to 7 temper or to limit the amount of force; the severity of the security problem at issue; the 8 threat reasonably perceived by the officer; and whether the plaintiff was actively 9 resisting.” Kingsley, 135 S. Ct. at 2473. 10 Because the Kingsley standard applicable to excessive force claims by pretrial 11 detainees is purely objective, it does not matter whether the defendant understood that 12 the force used was excessive or intended it to be excessive. Castro v. Cnty. of Los 13 Angeles, 833 F.3d 1060, 1069 (9th Cir. 2016) (en banc). A pretrial detainee can prevail 14 by providing “‘objective evidence that the challenged governmental action is not rationally 15 related to a legitimate governmental objective or that it is excessive in relation to that 16 purpose.’” Id. (quoting Kingsley, 135 S. Ct. at 2473-74)) (emphasis in original). 17 A claim for a violation of a pretrial detainee’s right to adequate medical care arises 18 under the Fourteenth Amendment rather than the Eighth Amendment. See Gordon v. 19 County of Orange, 888 F.3d 1118, 1122 & n.4 (9th Cir. 2018). The claim is evaluated 20 under an objective deliberate indifference standard.

21 [T]he elements of a pretrial detainee’s medical care claim against an individual defendant under the due process clause 22 of the Fourteenth Amendment are: (i) the defendant made an intentional decision with respect to the conditions under which 23 the plaintiff was confined; (ii) those conditions put the plaintiff at substantial risk of suffering serious harm; (iii) the defendant 24 did not take reasonable available measures to abate that risk, even though a reasonable official in the circumstances would 25 have appreciated the high degree of risk involved—making the consequences of the defendant’s conduct obvious; and (iv) by 26 not taking such measures, the defendant caused the plaintiff’s injuries. 27 Id. at 1125. With regard to the third element, a defendant’s conduct must be objectively 1 unreasonable – “a test that will necessarily ‘turn[] on the facts and circumstances of each 2 particular case.’” Id. (citation omitted). The four-part test described in Gordon requires 3 plaintiffs to prove more than negligence, but less than subjective intent – something akin 4 to reckless disregard. Id. 5 “Within the prison context, a viable claim of First Amendment retaliation entails five 6 basic elements: (1) An assertion that a state actor took some adverse action against an 7 inmate (2) because of (3) that prisoner's protected conduct, and that such action 8 (4) chilled the inmate's exercise of his First Amendment rights, and (5) the action did not 9 reasonably advance a legitimate correctional goal.” Rhodes v. Robinson, 408 F.3d 559

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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)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Graves v. Arpaio
623 F.3d 1043 (Ninth Circuit, 2010)
Michael Henry Ferdik v. Joe Bonzelet, Sheriff
963 F.2d 1258 (Ninth Circuit, 1992)
Rhodes v. Robinson
408 F.3d 559 (Ninth Circuit, 2005)
Shakur v. Schriro
514 F.3d 878 (Ninth Circuit, 2008)
Kingsley v. Hendrickson
576 U.S. 389 (Supreme Court, 2015)
Jonathon Castro v. County of Los Angeles
833 F.3d 1060 (Ninth Circuit, 2016)
Mary Gordon v. County of Orange
888 F.3d 1118 (Ninth Circuit, 2018)
Insurance Co. v. Ritchie
5 U.S. 541 (Supreme Court, 1866)
Hines v. Gomez
108 F.3d 265 (Ninth Circuit, 1997)
Freeman v. Arpaio
125 F.3d 732 (Ninth Circuit, 1997)
Ramirez v. Galaza
334 F.3d 850 (Ninth Circuit, 2003)

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Bluebook (online)
Tamrat v. Marlowe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tamrat-v-marlowe-cand-2021.