Tamrat v. Singh

CourtDistrict Court, N.D. California
DecidedMay 29, 2025
Docket3:24-cv-08591
StatusUnknown

This text of Tamrat v. Singh (Tamrat v. Singh) 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. Singh, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 HERMAN TAMRAT, Case No. 24-cv-08591-TLT

8 Plaintiff, ORDER OF SERVICE; DENYING 9 v. MOTION FOR INJUNCTIVE RELIEF; DENYING MOTION TO STAY 10 H. SINGH, et al., Re: Dkt. Nos. 13, 17 Defendants. 11

12 13 Plaintiff, a pretrial detainee at the San Francisco County Jail #2 proceeding pro se, filed a 14 civil rights complaint under 42 U.S.C. § 1983. For the reasons stated below, the complaint is 15 ordered served on defendants. Plaintiff has been granted leave to proceed in forma pauperis by 16 separate order. Plaintiff’s motions for injunctive relief and to stay the case will be denied. 17 DISCUSSION 18 1. Standard of Review 19 Federal courts must engage in a preliminary screening of cases in which prisoners seek 20 redress from a governmental entity, or from an officer or employee of a governmental entity. 28 21 U.S.C. § 1915A(a). In its review, the court must identify any cognizable claims, and dismiss any 22 claims which are frivolous, malicious, fail to state a claim upon which relief may be granted, or 23 seek monetary relief from a defendant who is immune from such relief. Id. at § 1915A(b)(1), (2). 24 Further, it should be noted that pleadings submitted by pro se parties must be liberally construed. 25 Balistreri v. 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 of the 27 claim showing that the pleader is entitled to relief.” While specific facts are not necessary, the 1 which it rests. Erickson v. Pardus, 551 U.S. 89, 93 (2007). Although a plaintiff need not include 2 detailed factual allegations in a complaint, the complaint must do more than recite elements of a 3 cause of action and state conclusions; rather, a plaintiff must state factual allegations sufficient to 4 raise the entitlement to relief “above the speculative level.” Bell Atlantic Corp. v. Twombly, 550 5 U.S. 544, 555 (2007). A complaint must proffer “enough facts to state a claim to relief that is 6 plausible on its face.” Id. at 570. The Supreme Court explained this standard: “[w]hile legal 7 conclusions can provide the framework of a complaint, they must be supported by factual 8 allegations . . . [and] [w]hen there are well-pleaded factual allegations, a court should assume their 9 veracity and then determine whether they plausibly give rise to an entitlement to relief.” Ashcroft 10 v. Iqbal, 556 U.S. 662, 679 (2009). 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 deprivation was committed by a person acting under the color of state law. West v. 14 Atkins, 487 U.S. 42, 48 (1988). 15 2. Plaintiff’s Claims 16 Plaintiff alleges that Deputy Singh used excessive force on him on July 6, 2024, in an 17 incident involving plaintiff reaching his arm through the food slot, and that Deputy Theodoris 18 failed to intervene in the use of excessive force. He alleges as follows: the deputies approached his 19 cell, and Singh tried to give plaintiff the wrong food. Plaintiff corrected him, and Singh stated 20 “You refused” and attempted to shut the cell’s tray slot. Plaintiff hurriedly placed his hand through 21 the tray-slot to stop Singh from closing it, and told Singh he wanted his food, and asked to speak 22 to a supervisor. Singh immediately grabbed plaintiff’s left wrist in a wrist-lock maneuver and 23 twisted it, bending plaintiff’s entire arm and banging his wrist against the sharp steel edges. He 24 almost broke plaintiff’s arm, if it weren’t for plaintiff turning his body with the deputy’s twisting 25 and agreeing to place his arm back inside his cell. 26 Plaintiff also alleges defendants denied him medical care after the incident and “walked 27 away” when he showed them his injuries but acknowledges that Theodoris summoned medical 1 limb x-ray” but has not named any radiologist as a defendant. 2 Plaintiff seeks to bring state-law claims of negligence, California’s Bane Act, intentional 3 and negligent infliction of emotional distress, and assault and battery as to defendant Singh. He 4 also alleges First Amendment retaliation. 5 Plaintiff seeks damages. 6 3. Analysis 7 a. Federal Claims 8 Liberally construed, plaintiff has stated a Fourteenth Amendment claim against Singh for 9 the use of force. See Kingsley v. Hendrickson, 576 U.S. 389, 397 (2015) (To prove an excessive 10 force claim under § 1983, a pretrial detainee must show only that the “force purposely or 11 knowingly used against him was objectively unreasonable.”). He has also stated a Fourteenth 12 Amendment claim against Theodoris for failure to intervene. The elements of a pretrial detainee’s 13 failure to intervene/protect claim under the Fourteenth Amendment are: (1) the defendant made an 14 intentional decision with respect to the conditions under which the plaintiff was confined; (2) 15 those conditions put the plaintiff at substantial risk of suffering serious harm; (3) the defendant did 16 not take reasonable available measures to abate that risk, even though a reasonable official in the 17 circumstances would have appreciated the high degree of risk involved; and (4) by not taking such 18 measures, the defendant caused plaintiff’s injuries. Castro v. County of Los Angeles, 833 F.3d 19 1060, 1071 (9th Cir. 2016). “[A] pretrial detainee who asserts a due process claim for failure to 20 protect [must] prove more than negligence but less than subjective intent—something akin to 21 reckless disregard.” Id. 22 Plaintiff has not stated a claim for denial of medical care because it appears from his 23 allegations that he received medical care relatively promptly, and he has not alleged any injury 24 caused by any delay. He has not stated a First Amendment claim because he does not allege that 25 he was engaged in any conduct protected by the First Amendment. 26 b. State-Law Claims 27 i. Negligence/Negligent Infliction of Emotional Distress 1 these claims falls under the category of general negligence. Lawson v. Mgmt. Activities, Inc., 69 2 Cal. App. 4th 652, 657 (1999). The tort of negligence requires duty, breach, causation, and harm. 3 Id. “[A] jail guard does have a duty to protect inmates, [which] extends only to reasonably 4 foreseeable harm.” Harding v. City & Cnty. of San Francisco, 602 F. App’x 380, 383 (9th Cir. 5 2015) (citing Giraldo v. Cal. Dep’t of Corrs. & Rehab., 168 Cal.App.4th 231, 245 (2008)). 6 Because it is foreseeable that plaintiff would suffer emotional distress resulting from an excessive 7 use of force incident, plaintiff has stated a cognizable negligence claim against defendant Singh. 8 ii.

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