Washington v. Serrato

CourtDistrict Court, N.D. California
DecidedMarch 28, 2023
Docket5:22-cv-05832
StatusUnknown

This text of Washington v. Serrato (Washington v. Serrato) 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
Washington v. Serrato, (N.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 TRACYE BENARD WASHINGTON, 11 Case No. 22-cv-05832 BLF (PR) Plaintiff, 12 ORDER OF PARTIAL DISMISSAL v. AND DISMISSAL WITH LEAVE TO 13 AMEND J. SERRATO, et al., 14 Defendants. 15

16 17 18 Plaintiff, a California inmate, filed the instant pro se civil rights action pursuant to 19 42 U.S.C. § 1983 against prison staff at Salinas Valley State Prison (“SVSP”) where he 20 was formerly housed. Dkt. No. 1-1. He has since been moved to Kern Valley State 21 Prison. Dkt. No. 6. Plaintiff has paid the filing fee. Id. 22 23 DISCUSSION 24 I. 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 governmental entity. See 28 U.S.C. § 1915A(a). In its review, the court must identify any 1 upon which relief may be granted or seek monetary relief from a defendant who is immune 2 from such relief. See id. § 1915A(b)(1),(2). Pro se pleadings must, however, be liberally 3 construed. See Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). 4 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege two essential 5 elements: (1) that a right secured by the Constitution or laws of the United States was 6 violated, and (2) that the alleged violation was committed by a person acting under the 7 color of state law. See West v. Atkins, 487 U.S. 42, 48 (1988). 8 To state a claim that is plausible on its face, a plaintiff must allege facts that 9 “allow[] the court to draw the reasonable inference that the defendant is liable for the 10 misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). From these decisions, 11 the following “two principles” arise: “First to be entitled to the presumption of truth, 12 allegations in a complaint or counterclaim may not simply recite the elements of a cause of 13 action but must contain sufficient allegations of underlying facts to give fair notice and to 14 enable the opposing party to defend itself effectively. Second, the factual allegations that 15 are taken as true must plausibly suggest an entitlement to relief, such that it is not unfair to 16 require the opposing party to be subjected to the expense of discovery and continued 17 litigation.” Starr v. Baca, 652 F.3d 1202, 1216 (9th Cir. 2011) 18 II. Plaintiff’s Claims 19 The events underlying this complaint occurred at SVSP, and involved Correctional 20 Officers J. Serrato, E. Guijarro, C. Diaz, and Sgt. B. Akin. Dkt. No. 1-1 at 2, 4. On June 21 19, 2022, Plaintiff claims he had a short but antagonistic exchange with Officers Serrato 22 and Diaz regarding various complaints. Id. at 6-7. Moments later, Defendants Serrato 23 came to Plaintiff’s cell with Sgt. Akin, and began pepper-spraying Plaintiff, hitting him 24 directly in the face and continuing “for an exceedingly long period of time.” Id. at 8. 25 Plaintiff was sitting in his wheelchair at the time. Id. Then Plaintiff felt someone, who 26 was later identified as Officer Guijarro, place their hands to the back of his neck and push 1 struck in his left rib cage area. Id. at 9. He was then handcuffed behind his back and 2 dragged forward by his arms. Id. Plaintiff was taken to the prison’s Triage Treatment 3 Area, and then an hour later, taken to Natividad Hospital Emergency Trauma Center for 4 treatment. Id. at 12. Plaintiff returned to prison approximately four hours later and was 5 informed that he was on “ad-seg” status; his cell had been cleaned out and all his personal 6 property had been removed. Id. at 14. 7 The next day, June 20, 2022, Plaintiff was informed that he was being charged with 8 battery on a peace officer based on Officer Serrato’s claim that Plaintiff threw his 9 wheelchair leg at him when his cell door was opened and that Plaintiff had struck Officer 10 Serrato in the face as he was attempting to subdue Plaintiff in his wheelchair. Id. Plaintiff 11 was placed in ad-seg that day. Id. The Rules Violation Report (“RVR”) was prepared by 12 Officer Diaz. Id. at 20. 13 Based on these allegations, Plaintiff claims the following: (1) he was subject to 14 excessive force under the Eighth Amendment; (2) his rights under the American with 15 Disabilities Act (“ADA”) and the Rehabilitation Act were violated; (3) Defendants 16 conspired to assault him; and (4) his rights under the 1965 Civil Rights Act were violated 17 based on racial prejudice. Dkt. No. 1-1 at 17-20. Plaintiff seeks damages and injunctive 18 relief in the form of body cameras on SVSP guards. Id. at 20-21. Plaintiff also seeks a 19 restraining order. Id. at 21. 20 A. Excessive Force 21 Plaintiff claims Defendants Serrato, Guijarro, and Akin used unnecessary and 22 excessive force against him when they pepper-sprayed him without cause or provocation, 23 causing serious bodily injury. Dkt. No. 1-1 at 17-19. 24 The treatment a convicted prisoner receives in prison and the conditions under 25 which he is confined are subject to scrutiny under the Eighth Amendment. Helling v. 26 McKinney, 509 U.S. 25, 31 (1993). “After incarceration, only the unnecessary and wanton 1 Amendment.” Whitley v. Albers, 475 U.S. 312, 319 (1986) (ellipsis in original) (internal 2 quotation and citation omitted). Whenever prison officials stand accused of using 3 excessive force in violation of the Eighth Amendment, the deliberate indifference standard 4 is inappropriate. Hudson v. McMillian, 503 U.S. 1, 6 (1992). Instead, the core judicial 5 inquiry is whether force was applied in a good-faith effort to maintain or restore discipline, 6 or maliciously and sadistically to cause harm. Id. at 6-7; Whitley, 475 U.S. at 320-21; 7 Jeffers v. Gomez, 267 F.3d 895, 912-13 (9th Cir. 2001) (applying “malicious and sadistic” 8 standard to claim that prison guards used excessive force when attempting to quell a prison 9 riot, but applying “deliberate indifference” standard to claim that guards failed to act on 10 rumors of violence to prevent the riot). 11 Liberally construed, Plaintiff states a cognizable excessive force claim based on the 12 unjustified force by Defendants Serrato, Guijarro, and Akin. 13 B. ADA and Rehabilitation Act 14 Plaintiff claims Defendants are liable for violating his rights as a disabled person 15 under the ADA based on the incident. 16 The Americans with Disabilities Act (“ADA”), 42 U.S.C. §§ 12101 et seq., and the 17 Rehabilitation Act of 1973 (“RA”), 29 U.S.C. §§ 701 et seq., prohibit discrimination 18 against an otherwise qualified individual based on his or her disability. “The [RA], the 19 precursor to the ADA, applies to federal agencies, contractors and recipients of federal 20 financial assistance, while the ADA applies to private employers with over 15 employees 21 and state and local governments.” Calero-Cerezo v. U.S., Dep’t of Justice, 355 F.3d 6

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Bluebook (online)
Washington v. Serrato, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-serrato-cand-2023.