Ward v. Lovell

CourtDistrict Court, S.D. California
DecidedSeptember 18, 2025
Docket3:24-cv-01400
StatusUnknown

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

Bluebook
Ward v. Lovell, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 WAYNE WARD, Case No.: 3:24-cv-1400-RSH-MSB CDCR #BK-3300, 12 ORDER (1) CONSTRUING ECF NO. Plaintiff, 13 8 AS A FIRST AMENDED vs. COMPLAINT AND 14

15 (2) DISMISSING FIRST AMENDED J. LOVELL, E. GUEVARA, C. COMPLAINT WITHOUT 16 MARTINEZ, R. ALLEN, J. MAGNAR, PREJUDICE FOR FAILURE TO 17 Defendants. COMPLY WITH FED. R. CIV. P. 8 AND FAILURE TO STATE A 18 CLAIM PURSUANT TO 28 U.S.C. 19 §§ 1915(e)(2)(B)(ii) & 1915A(b)(1)

20 I. INTRODUCTION 21 Plaintiff Wayne Ward (“Plaintiff” or “Ward”) is a state inmate proceeding pro se 22 with a civil rights action pursuant to 42 U.S.C. § 1983. In his original complaint, Ward 23 alleged Defendants violated his Eighth Amendment rights by using excessive force against 24 him and failing to provide him with medical care after he was injured. See ECF No. 1. On 25 May 7, 2025, the Court granted Plaintiff’s request to proceed in forma pauperis and 26 dismissed the original complaint without prejudice for failure to state a claim. See ECF No. 27 7. The Court granted Ward leave to file an amended complaint by June 21, 2025. Id. at 7. 28 1 On June 20, 2025, Ward filed a 2-page “letter” (ECF No. 8), which this Court now 2 liberally CONSTRUES as a First Amended Complaint (“FAC”). See Hebbe v. Pliler, 627 3 F.3d 338, 342 (9th Cir. 2010) (stating courts must “construe pro se filings liberally”); see 4 also Teal v. Vargo, 9 F. App’x 718, 719 (9th Cir. 2001) (concluding district court 5 reasonably construed document entitled “narrative summary” as an amended complaint 6 when it was the only document filed by pro se plaintiff after leave to amend was granted). 7 For the reasons discussed below, the Court dismisses the FAC without prejudice and 8 with leave to amend. 9 II. SCREENING PURSUANT TO 28 U.S.C. §§ 1915(e)(2)(B) & 1915A(b) 10 A. Legal Standard 11 Plaintiff is proceeding in forma pauperis and as such, the Court must screen the FAC 12 and dismiss it to the extent that it is frivolous, malicious, fails to state a claim, or seeks 13 damages from defendants who are immune. See 28 U.S.C. §§ 1915(e)(2)(B) and 1915A(b). 14 “The standard for determining whether Plaintiff has failed to state a claim upon which relief 15 can be granted under § 1915(e)(2)(B)(ii) is the same as the Federal Rule of Civil Procedure 16 12(b)(6) standard for failure to state a claim.” Watison v. Carter, 668 F.3d 1108, 1112 (9th 17 Cir. 2012). Rule 12(b)(6) requires that a complaint “contain sufficient factual matter . . . to 18 state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 19 (2009) (internal quotation marks omitted). While detailed factual allegations are not 20 required, “[t]hreadbare recitals of the elements of a cause of action, supported by mere 21 conclusory statements, do not suffice” to state a claim. Id. The “mere possibility of 22 misconduct” or “unadorned, the defendant-unlawfully-harmed-me accusation[s]” fall short 23 of meeting this plausibility standard. Id. 24 B. Plaintiff’s Allegations 25 The factual allegations in the FAC are sparse. Ward states that on January 15, 2023, 26 Officer Lovell “use[d] excessive force on [him].” ECF No. 8 at 1. He alleges he was 27 “complying with [Lovell] and Officer Guevara when [he] was slapped into a bench in the 28 1 dayroom.” Id. When Ward fell onto the bench, he hit his head and shoulder. He still suffers 2 from pain as a result. Id. Ward further states that “prison employees C. Martinez, R. Allen 3 and J. Magnar refused me medical care by saying I would receive care later.” Id. 4 C. Discussion 5 1. Rule 8 6 Federal Rule of Civil Procedure 8(a) requires a complaint provide “a short and plain 7 statement of the claim showing that the pleader is entitled to relief,” sufficient to “give the 8 defendant fair notice of what the . . . claim is and the grounds upon which it rests.” Bell 9 Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citation omitted). “Factual allegations 10 must be enough to raise a right to relief above the speculative level.” Id. A pleading that 11 merely alleges “naked assertion[s] devoid of further factual enhancement” is insufficient 12 to comply with Rule 8. Iqbal, 556 U.S. at 678 (citation and internal quotation marks 13 omitted). 14 Here, the FAC contains little more than conclusory statements, with very few 15 specific facts. While not entirely clear, the FAC appears to be an attempt by Ward to 16 address a deficiency discussed in this Court’s May 7, 2025 screening order, which noted 17 that Ward had failed to tie any specific conduct to any named defendant. ECF No. 7 at 4– 18 5. In his FAC, Ward makes clear he is suing defendants Lovell and Guevara for excessive 19 force and defendants Martinez, Allen and Magar for failure to provide him with medical 20 care. ECF No. 8 at 1. But beyond that, the FAC is nearly devoid of specific facts regarding 21 the details of the alleged incident(s) and/or Ward’s injuries. While Ward’s original 22 complaint contained some of these specifics, an amended complaint replaces any prior 23 complaint, which is “treated thereafter as non-existent.” See Ramirez v. Cnty. of San 24 Bernardino, 806 F.3d 1002, 1008 (9th Cir. 2015) (internal citations omitted). Thus, because 25 the FAC is not complete in itself, and contains only conclusory assertions “devoid of 26 27 28 1 further factual enhancement,” it is insufficient to comply with Rule 8. Iqbal, 556 U.S. at 2 678 (citation and internal quotation marks omitted); see also Ivey v. Bd. of Regents of Univ. 3 of Alaska, 673 F.2d 266, 268 (9th Cir. 1982) (stating that “liberal interpretation of a civil 4 rights complaint may not supply essential elements of the claim that were not initially 5 pled”). 6 Therefore, the Court DISMISSES the First Amended Complaint without prejudice 7 and with leave to amend, for failure to comply with Rule 8 and failure to state a claim. See 8 Fed. R. Civ. P. 8(a); see also 28 U.S.C. §§ 1915(e)(2)(B)(ii) & 1915A(b)(1). 9 2. Legal Standards 10 Should Plaintiff seek to amend, the Court again provides the following legal 11 standards for Eighth Amendment excessive force and medical care claims raised pursuant 12 to 42 U.S.C. § 1983: 13 a. 42 U.S.C. § 1983

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Ward v. Lovell, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ward-v-lovell-casd-2025.