Tamrat v. Marlowe

District Court, N.D. California·Decided May 13, 2021·No. 4:20-cv-07623·Unknown

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 DISMISSING CLAIMS; 9 v. DENYING MOTION TO APPOINT COUNSEL; GRANTING EXTENSION 10 ADAM MARLOWE, et al., Re: Dkt. Nos. 19, 21 Defendants. 11

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

23 [T]he elements of a pretrial detainee’s medical care claim against an individual defendant under the due process clause 24 of the Fourteenth Amendment are: (i) the defendant made an intentional decision with respect to the conditions under which 25 the plaintiff was confined; (ii) those conditions put the plaintiff at substantial risk of suffering serious harm; (iii) the defendant 26 did not take reasonable available measures to abate that risk, even though a reasonable official in the circumstances would 27 have appreciated the high degree of risk involved—making the injuries. 1 Id. at 1125. With regard to the third element, a defendant’s conduct must be objectively 2 unreasonable – “a test that will necessarily ‘turn[] on the facts and circumstances of each 3 particular case.’” Id. (citation omitted). The four-part test described in Gordon requires 4 plaintiffs to prove more than negligence, but less than subjective intent – something akin 5 to reckless disregard. Id. 6 Plaintiff states that on June 9, 2019, defendant deputies Marlowe and Tamayo 7 knocked plaintiff to the ground and then grabbed his hands, wrists and arms painfully 8 bending them and causing injuries. He also alleges that he was slammed on the ground 9 injuring his head and later shoved into a doorframe. The case continues with these 10 allegations of excessive force against defendants Marlowe and Tamayo.

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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)
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)