Ward v. Lovell

District Court, S.D. California·Decided September 18, 2025·No. 3:24-cv-01400·Unknown

Opinion

WAYNE WARD, Case No.: 3:24-cv-1400-RSH-MSB CDCR #BK-3300, ORDER (1) CONSTRUING ECF NO. Plaintiff, 8 AS A FIRST AMENDED vs. COMPLAINT AND

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

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

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