Summary
The United States District Court for the Eastern District of California screens Jeremy Jones’s second amended 42 U.S.C. § 1983 complaint. The court finds plausible Eighth Amendment conditions-of-confinement and medical-care claims, Fourteenth Amendment due-process claims, and First Amendment retaliation claims against specified prison officials, while recommending dismissal of certain claims and defendants. The document directs the Clerk to assign a district judge and sets a 14-day deadline for objections.
Topics
Practice areas
Questions Presented
- Whether the second amended complaint states a cognizable Eighth Amendment conditions-of-confinement claim based on denial of a dark, quiet space and outdoor exercise.
- Whether the second amended complaint states a Fourteenth Amendment due process claim based on alleged denial of witnesses, a defense, staff assistance, and a fair disciplinary or classification hearing.
- Whether the second amended complaint states a First Amendment retaliation claim based on allegedly retaliatory searches, disciplinary reports, labeling Jones a snitch, and adverse hearing conduct after Jones filed grievances.
- Whether the second amended complaint states an Eighth Amendment deliberate-indifference claim based on alleged denial or interference with medically indicated accommodations and treatment.
- Whether the remaining allegations, including deprivation of a television, radio, and hotpot and the alleged relocation that preceded COVID-19 infection, state cognizable constitutional claims.
Holdings
- The second amended complaint plausibly states an Eighth Amendment conditions-of-confinement claim against Jimenez because it alleges that Jimenez knowingly refused to allow Jones to cover his back window despite a documented photophobia condition, debilitating migraines, and medical instructions to lie in a dark, quiet room.
- The second amended complaint plausibly states due process claims against Goree, Brown, Thomas, Cortez, and Valdez based on alleged denial of the opportunity to call witnesses, present a defense, and obtain staff or legal assistance during disciplinary and classification proceedings, absent a legitimate penological justification.
- The second amended complaint plausibly states First Amendment retaliation claims against Jimenez and Brown.
- The second amended complaint plausibly states deliberate-indifference claims against Jackson, Castro, Igbinosa, Ahlmeyer, Grewal, Pena, Mejia, Montes, Navarro, Serda, Stovall, and an unidentified on-call physician.
- The second amended complaint plausibly states an Eighth Amendment conditions-of-confinement claim against Goree based on alleged long-term deprivation of outdoor exercise.
- The allegations concerning the loss of a television, radio, and hotpot do not state an Eighth Amendment claim, and the allegations against the RAP panel members and Hernandez concerning housing relocation and COVID-19 infection fail to state a claim because the alleged causal connection is too attenuated.
Key quotations
“To establish a violation of this duty, a prisoner must first demonstrate an objectively serious deprivation, one that amounts to the denial of “the minimal civilized measures of life’s necessities.”” (at 10)
“The minimum procedural requirements that must be met are: (1) written notice of the charges; (2) at least 24 hours between the time the prisoner receives written notice and the time of the hearing, so that the prisoner may prepare his defense; (3) a written statement by the fact finders of the evidence they rely on and reasons for taking disciplinary action; (4) the right of the prisoner to call witnesses and present documentary evidence in his defense, when permitting him to do so would not be unduly hazardous to institutional safety or correctional goals; and (5) legal assistance to the prisoner where the prisoner is illiterate or the issues presented are legally complex.” (at 13-14)
“A claim for First Amendment retaliation in the prison context requires: (1) that a state actor took some adverse action against the plaintiff (2) because of (3) the plaintiff’s protected conduct, and that such action (4) chilled the plaintiff’s exercise of his First Amendment rights, and (5) “the action did not reasonably advance a legitimate correctional goal.”” (at 18)
Factual background
Jones is a California state prisoner at Kern Valley State Prison who alleges debilitating migraines, photophobia/photosensitivity, and related mental-health symptoms. He alleges that prison officials denied accommodations and medical measures, restricted outdoor exercise, subjected him to disciplinary proceedings, and retaliated against him after he filed grievances. The court found plausible claims concerning prison conditions, disciplinary-process protections, retaliation, and deliberate indifference to serious medical needs, but found other allegations insufficiently connected to the defendants or constitutionally insufficient.
Procedural history
Jones, proceeding pro se and in forma pauperis, filed a § 1983 action and later a first amended complaint. After a screening order identified some cognizable claims and gave Jones the option to proceed, amend, or voluntarily dismiss, Jones filed a second amended complaint. The magistrate judge recommends that the action proceed on specified First, Eighth, and Fourteenth Amendment claims, that the remaining claims be dismissed, and that defendant Hernandez be dismissed.