Turner v. West County Detention Facility

CourtDistrict Court, N.D. California
DecidedNovember 8, 2022
Docket5:22-cv-03396
StatusUnknown

This text of Turner v. West County Detention Facility (Turner v. West County Detention Facility) 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
Turner v. West County Detention Facility, (N.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 CURTIS TURNER, 11 Case No. 22-cv-03396 BLF (PR) Plaintiff, 12 ORDER OF DISMISSAL WITH v. LEAVE TO AMEND 13

14 WEST COUNTY DETENTION FACILITY, et al., 15 Defendants. 16

18 Plaintiff, who is currently confined at the West County Detention Facility 19 (“WCDF”) in Contra Costa County, filed a civil rights complaint pursuant to 42 U.S.C. § 20 1983 against WCDF and an unidentified WCDF deputy. Dkt. No. 1. Plaintiff’s motion for 21 leave to proceed in forma pauperis will be addressed in a separate order. 22

23 DISCUSSION 24 A. Standard of Review 25 A federal court must conduct a preliminary screening in any case in which a 26 prisoner seeks redress from a governmental entity or officer or employee of a 27 1 cognizable claims and dismiss any claims that are frivolous, malicious, fail to state a claim 2 upon which relief may be granted or seek monetary relief from a defendant who is immune 3 from such relief. See id. § 1915A(b)(1),(2). Pro se pleadings must, however, be liberally 4 construed. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 5 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 6 elements: (1) that a right secured by the Constitution or laws of the United States was 7 violated, and (2) that the alleged violation was committed by a person acting under the 8 color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). 9 B. Plaintiff’s Claims 10 Plaintiff claims that on July 10, 2021, he was assaulted by a deputy at WCDF. Dkt. 11 No. 1-1 at 1. Plaintiff claims while in his cell, he made a request for assistance from the 12 deputy which lead to a hostile exchange of words. Id. The deputy then entered Plaintiff’s 13 cell, ordered him to lie down on his stomach, and then kicked Plaintiff in the mouth, 14 resulting in a busted lip and several broken teeth. Id. Plaintiff claims that the deputy then 15 searched his cell for contraband and found none. Id. at 2. Other than bringing him a cup 16 of water for his injuries, the deputy refused to get Plaintiff medical or dental treatment. Id. 17 Plaintiff seeks a settlement for monetary damages. Id. at 3. 18 Liberally construed, Plaintiff’s allegations indicate that he may have cognizable 19 claims for excessive force and inadequate medical treatment. However, his allegations are 20 insufficient to move forward with these claims because he must explain his custody status 21 at the time of the incident, i.e., whether he was a pre- or post- arraignment pretrial detainee 22 or a convicted prisoner, which is necessary to determine whether his claims sound under 23 the Eighth Amendment or the Fourteenth Amendment. See e.g., Helling v. McKinney, 509 24 U.S. 25, 31 (1993) (treatment convicted prisoner receives in prison and conditions under 25 which he is confined subject to scrutiny under the Eighth Amendment); Graham v. 26 Connor, 490 U.S. 386, 395 n.10 (1989) (citing Bell v. Wolfish, 441 U.S. 520, 535-39 1 detainee from use of excessive force that amounts to punishment); cf. Pierce v. Multnomah 2 County, Oregon, 76 F.3d 1032, 1043 (9th Cir. 1996) (4th Amendment reasonableness 3 standard applies to allegations of use of excessive force against pre-arraignment detainee). 4 Furthermore, Plaintiff has failed to provide the name of the deputy responsible for 5 his injuries. That information is necessary for this matter to be served on the proper 6 defendant. The Court notes Plaintiff refers to an appeal that was filed at the third level 7 which was answered by “Sgt. Cogo & Lawson” regarding this matter. Dkt. No. 1 at 2. 8 Plaintiff may look to the copy of that appeal to see whether the identify of the deputy can 9 be ascertained or seek that information from those individuals. 10 Lastly, Plaintiff also names the WCDF as a defendant but makes no specific 11 allegations against this entity. Dkt. No. 1 at 2. If Plaintiff is attempting to hold WCDF, or 12 Contra Costa County, responsible for the deputy’s actions, he must state sufficient facts to 13 establish liability. Local governments are “persons” subject to liability under 42 U.S.C. § 14 1983 where official policy or custom causes a constitutional tort, see Monell v. Dep't of 15 Social Servs., 436 U.S. 658, 690 (1978);1 however, a city or county may not be held 16 vicariously liable for the unconstitutional acts of its employees under the theory of 17 respondeat superior, see Board of Cty. Comm'rs. of Bryan Cty. v. Brown, 520 U.S. 397, 18 403 (1997); Monell, 436 U.S. at 691; Fuller v. City of Oakland, 47 F.3d 1522, 1534 (9th 19 Cir. 1995). 20 To impose municipal liability under § 1983 for a violation of constitutional rights 21 resulting from governmental inaction or omission, a plaintiff must show: “(1) that he 22 possessed a constitutional right of which he or she was deprived; (2) that the municipality 23 had a policy; (3) that this policy amounts to deliberate indifference to the plaintiff’s 24 constitutional rights; and (4) that the policy is the moving force behind the constitutional 25 1 Local governing bodies therefore may be sued directly under § 1983 for monetary, 26 declaratory or injunctive relief for the violation of federal rights. See Monell, 436 U.S. at 1 violation.” Oviatt By and Through Waugh v. Pearce, 954 F.2d 1470, 1474 (9th Cir. 1992) 2 (quoting City of Canton v. Harris, 489 U.S. 378, 389 (1989) (internal quotation marks 3 omitted); see Plumeau v. School Dist. #40 County of Yamhill, 130 F.3d 432, 438 (9th Cir. 4 1997). 5 “Official municipal policy includes the decisions of a government’s lawmakers, the 6 acts of its policymaking officials, and practices so persistent and widespread as to 7 practically have the force of law.” Connick v. Thompson, 563 U.S. 51, 61 (2011).

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Related

Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
City of Oklahoma v. Tuttle
471 U.S. 808 (Supreme Court, 1985)
West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
City of Canton v. Harris
489 U.S. 378 (Supreme Court, 1989)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Michael Henry Ferdik v. Joe Bonzelet, Sheriff
963 F.2d 1258 (Ninth Circuit, 1992)
James Gillette v. Duane Delmore, and City of Eugene
979 F.2d 1342 (Ninth Circuit, 1992)
Plumeau v. School District #40
130 F.3d 432 (Ninth Circuit, 1997)
Connick v. Thompson
179 L. Ed. 2d 417 (Supreme Court, 2011)

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Turner v. West County Detention Facility, Counsel Stack Legal Research, https://law.counselstack.com/opinion/turner-v-west-county-detention-facility-cand-2022.