VanderWeken v. Davis

CourtDistrict Court, D. Idaho
DecidedOctober 6, 2025
Docket1:25-cv-00305
StatusUnknown

This text of VanderWeken v. Davis (VanderWeken v. Davis) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
VanderWeken v. Davis, (D. Idaho 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

JACOB NATHANIEL VANDERWEKEN, Case No. 1:25-cv-00305-BLW

Plaintiff, INITIAL REVIEW ORDER BY SCREENING JUDGE v.

TY DAVIS; DEPUTY WARDEN MARTINEZ; C/O VAUGHN; VSC TOMLINSON; C/O SOMERS; and VSC BOROSSO,

Defendants.

The Clerk of Court conditionally filed Plaintiff Jacob Nathaniel VanderWeken’s Complaint because of Plaintiff’s status as an inmate and in forma pauperis request. A “conditional filing” means that a plaintiff must obtain authorization from the Court to proceed. Upon screening, the Court must dismiss claims that are frivolous or malicious, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b). Having reviewed the record, the Court concludes that the Complaint fails to state a claim upon which relief may be granted. Accordingly, the Court enters the following Order directing Plaintiff to file an amended complaint if Plaintiff intends to proceed.

1. Standards of Law for Screening Complaints A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). A complaint fails to state a claim for relief under Rule 8 if the factual assertions in the complaint, taken

as true, are insufficient for the reviewing court plausibly “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

To state an actionable claim, a plaintiff must provide “enough factual matter (taken as true) to suggest” that the defendant committed the unlawful act, meaning that sufficient facts are pled “to raise a reasonable expectation that discovery will reveal evidence of illegal [activity].” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 556

(2007). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’” Iqbal, 556 US. at 678 (quoting Twombly, 550 U.S. at 555).

The Court liberally construes the pleadings to determine whether a case should be dismissed for a failure to plead sufficient facts to support a cognizable legal theory or for the absence of a cognizable legal theory. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable factual and legal basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989) (discussing Federal Rule of Civil Procedure 12(b)(6)), superseded by statute on

other grounds as stated in Lopez v. Smith, 203 F.3d 1122, 1130 (9th Cir. 2000). 2. Factual Allegations Plaintiff is a prisoner in the custody of the Idaho Department of Correction, currently incarcerated at the Idaho State Correctional Center (“ISCC”). Plaintiff’s

claims arose when Plaintiff was incarcerated the Idaho State Correctional Institution (“ISCI”). Plaintiff states that, in March 2025, he was improperly issued a disciplinary

offense report (“DOR”) for walking too slowly. Compl., Dkt. 3, at 5. Plaintiff was on his way to breakfast when Defendant Correctional Officer Vaughn told Plaintiff to walk faster. Plaintiff continued to walk slowly because he was in pain from an ankle injury. Vaughn later stated he did not see Plaintiff limping from an injury

and issued Plaintiff the DOR for failing to walk faster when ordered. In March and April 2025, while Plaintiff was attending chapel services and sitting next to another inmate who was Plaintiff’s friend, Defendant Correctional

Officer Somers “targeted” and “maliciously harassed” Plaintiff by ordering the two inmates to separate because they were too close to each other. Id. at 7. Plaintiff responded that they were not violating any prison regulations, and Somers threatened to “write [Plaintiff] up.” Id. Later, Plaintiff was attending chapel services and was again sitting next to his friend. Defendant Volunteer Service Coordinator Tomlinson told Plaintiff he

was not allowed to sit next to the other inmate because they were talking and being disruptive. Id. at 6. Tomlinson also allegedly threatened Plaintiff with being “permanently” excluded from chapel services. When Plaintiff objected that

Tomlinson could not do that, Tomlinson stated, “I can do what I want,” and called Plaintiff and the other inmate “morons.” Id. Plaintiff does not contend that he was actually excluded from chapel services. Plaintiff submitted concern forms about these chapel issues, as well as a

problem with Plaintiff not being called up to attend classes, to Defendant Chaplain Borosso. Id. at 3. It appears Borosso either did not respond to the concern forms or responded in a manner that was unsatisfactory to Plaintiff.

Plaintiff also alleges that Defendant Deputy Warden Martinez transferred Plaintiff from ISCI to ISCC in retaliation for Plaintiff’s use of the grievance process. Specifically, Plaintiff had complained in a concern form that ISCI staff were harassing Plaintiff by making sexual comments and telling him he could not

sit next to his friend during chapel services. Id. at 3. After Plaintiff submitted the concern form, he was transferred. Id. at 3–4. Defendant Warden Davis allegedly “allowed” Martinez to make the transfer. Id. at 3. Plaintiff asserts claims under the federal civil rights statute, 42 U.S.C. § 1983, as well as the Religious Land Use and Institutionalized Persons Act

(“RLUIPA”), 42 U.S.C. § 2000cc et seq., and the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101 et seq., Plaintiff also brings negligence claims under Idaho state law. Compl. at 3–8.

3. Discussion Plaintiff has not stated a claim upon which relief may be granted. The Court will, however, grant Plaintiff 28 days to amend the Complaint. Any amended complaint should take into consideration the following.

A. Section 1983 Claims Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To state a plausible civil rights claim, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by

conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). A defendant causes a constitutional deprivation within the meaning of § 1983 “if he does an affirmative act, participates in another’s affirmative acts, or omits to perform an act which he is legally required to do that

causes the deprivation.” Johnson v. Duffy, 588 F.2d 740, 743 (9th Cir. 1978). That is, prison officials generally are not liable for damages in their individual capacities under § 1983 unless they personally participated in the alleged constitutional violations. Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989); see also Iqbal, 556 U.S. at 677 (“[E]ach Government official, his or her title

notwithstanding, is only liable for his or her own misconduct.”). Section 1983 does not allow for recovery against an employer or principal simply because an employee or agent committed misconduct. Taylor, 880 F.2d at 1045.

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