Willard v. Officer Ransom

CourtDistrict Court, D. Idaho
DecidedAugust 25, 2021
Docket1:21-cv-00159
StatusUnknown

This text of Willard v. Officer Ransom (Willard v. Officer Ransom) 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
Willard v. Officer Ransom, (D. Idaho 2021).

Opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO

CODY WILLARD, Case No. 1:21-cv-00159-DCN Plaintiff, INITIAL REVIEW ORDER BY vs. SCREENING JUDGE

OFFICER RANSOM, SERGEANT BONGIOVI, WARDEN CHRISTENSEN, et al.,

Defendants.

The Complaint of Plaintiff Cody Willard was conditionally filed by the Clerk of Court due to his status as a prisoner and pauper. Dkts. 3, 1. A “conditional filing” means that Plaintiff must obtain authorization from the Court to proceed. After reviewing the Complaint, the Court has determined that Plaintiff will be permitted to proceed. REVIEW OF COMPLAINT 1. Factual Allegations On or about October 19, 2020, Defendant Officer Ransom allegedly purposely or recklessly opened Plaintiff’s cell door and allowed inmate Wilson to enter and stab and beat Plaintiff. Wilson’s assault on Plaintiff caused three stab wounds, a broken hand, a neck injury, and continuing psychological and emotional injury. Plaintiff asserts federal civil rights and state law negligence claims. He seeks monetary damages and injunctive relief. 2. Standard of Law Under modern pleading standards, Federal Rule of Civil Procedure 8 requires a

complaint to “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The Iqbal/Twombly “facial plausibility” standard is met when a complaint contains “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct

alleged.” Id., citing Twombly, 550 U.S. at 556. A plaintiff must provide sufficient factual allegations to show that there is “more than a sheer possibility that a defendant has acted unlawfully.” Ibid. “Where a complaint pleads facts that are ‘merely consistent with’ a defendant’s liability, it ‘stops short of the line between possibility and plausibility of ‘entitlement to relief.’” Ibid.

In addition, the Prison Litigation Reform Act (PLRA)1 requires the Court to screen all pro se prisoner and pauper complaints to determine whether they have stated a claim upon which relief can be granted before such complaints are served on the defendants. 28 U.S.C. §§ 1915 & 1915A. The Court must dismiss any claims that are frivolous or malicious, that fail to state a claim upon which relief may be granted, or that seek monetary

relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). The Court liberally construes a plaintiff’s pleadings to determine whether the case

1 Pub. L. No. 104-134, 110 Stat. 1321, as amended, 42 U.S.C. § 1997e, et seq. should be dismissed for lack of a cognizable legal theory or a failure to plead sufficient facts to support a cognizable legal theory, under the Iqbal/Twombly standard. The critical inquiry is whether a constitutional claim, however inartfully pleaded, has an arguable legal

and factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th Cir. 1989). Plaintiff brings claims under 42 U.S.C. § 1983, the civil rights statute. To state a claim under § 1983, 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). For

Plaintiff’s purposes, 42 U.S.C. § 1983 is an implementing statute that makes it possible to bring a cause of action under the amendments of the United States Constitution. The Eighth Amendment to the United States Constitution protects prisoners against cruel and unusual punishment. To state a claim under the Eighth Amendment, Plaintiff must provide facts showing that he is “incarcerated under conditions posing a

substantial risk of serious harm,” or that he has been deprived of “the minimal civilized measure of life’s necessities” as a result of Defendants’ actions. Farmer v. Brennan, 511 U.S. 825, 834 (1994) (internal quotation marks omitted). Plaintiff must also allege facts showing that Defendants were deliberately indifferent to his needs. “[D]eliberate indifference entails something more than mere

negligence, [but] is satisfied by something less than acts or omissions for the very purpose of causing harm or with knowledge that harm will result.” Id. at 835. To exhibit deliberate indifference, a prison official “must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference.” Id. at 837. Prison officials who act with deliberate indifference “to the threat of serious harm or injury” by one prisoner against another are subject to liability under the Eighth

Amendment through § 1983. Berg v. Kincheloe, 794 F.2d 457, 459 (9th Cir. 1986). “Having incarcerated persons with demonstrated proclivities for antisocial criminal, and often violent, conduct, having stripped them of virtually every means of self-protection and foreclosed their access to outside aid, the government and its officials are not free to let the state of nature take its course.” Farmer, 511 U.S. at 833 (internal quotation marks, citation,

and alterations omitted). Although even an obvious danger does not result in liability if the official is not subjectively aware of it, a prison official cannot “escape liability for deliberate indifference by showing that, while he was aware of an obvious, substantial risk to inmate safety, he did not know that the complainant was especially likely to be assaulted by the specific prisoner who eventually committed the assault.” Id. at 843.

3. Discussion of Federal Claims A. Defendant Ransom

Plaintiff alleges that Defendant Ransom either purposely or recklessly opened Plaintiff’s cell door at the request of inmate Wilson, which led to the assault and injury of Plaintiff. He asserts that Defendant Ransom should not have let another inmate into Plaintiff’s cell because Plaintiff was housed in the protective custody unit for exactly that purpose—protection from other inmates. Plaintiff has stated sufficient allegations to proceed against Officer Ransom on Eighth Amendment individual capacity claims. B. Defendant Christensen i. Individual Capacity Claims for Monetary Damages Defendant Christensen was warden of the Idaho State Correctional Center (ISCC),

where Plaintiff was housed when he was attacked.

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Related

United Mine Workers of America v. Gibbs
383 U.S. 715 (Supreme Court, 1966)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Keith A. Berg v. Larry Kincheloe
794 F.2d 457 (Ninth Circuit, 1986)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Nelson v. Anderson Lumber Co.
99 P.3d 1092 (Idaho Court of Appeals, 2004)
Starr v. Baca
652 F.3d 1202 (Ninth Circuit, 2011)

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