Damon Crist v. Deputy Miller; Deputy Ryan Cirilo; Deputy Padlo; Deputy Love; Deputy Scruggs; and Deputy John Doe

Summary

The United States District Court for the District of Idaho screened Damon Crist’s First Amended Complaint under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A. The court concluded that Crist failed to state plausible claims for failure to protect, equal protection, or First Amendment retaliation, but granted him 28 days to file a second amended complaint.

Holdings

1. Crist failed to plausibly allege that Miller or the unidentified defendant intentionally decided not to address a substantial risk of serious harm arising from other inmates' access to his criminal-discovery documents.
2. Crist failed to plausibly allege that Miller's response to his generalized fear of gang members constituted objective deliberate indifference to a substantial risk of serious harm.
3. Crist failed to state an equal-protection claim because he did not plausibly allege that the other inmates were similarly situated, that defendants acted with invidious discrimination, or that the differential treatment lacked a rational basis.
4. Crist failed to state retaliation claims against Padlo, Love, and Cirilo because he did not plausibly allege their knowledge of his protected conduct, a causal connection between that conduct and the housing decisions, or the absence of legitimate penological reasons for those decisions.
5. Crist failed to state a retaliation claim against Scruggs because the complaint did not plausibly allege that Scruggs lied about the attack video or acted because of Crist's protected conduct.
6. The court granted Crist 28 days to file a second amended complaint curing the identified deficiencies, or alternatively to file a notice of voluntary dismissal.
7. The court denied Crist's motion to stay the case for 180 days.

Questions Presented

1. Whether Crist plausibly stated a Fourteenth Amendment failure-to-protect claim against Deputy Miller and an unidentified defendant.
2. Whether Crist plausibly stated an equal-protection claim based on his delayed transfer to less restrictive housing.
3. Whether Crist plausibly stated First Amendment retaliation claims against Deputies Padlo, Love, Cirilo, and Scruggs.
4. Whether Crist should be granted leave to file a second amended complaint after the First Amended Complaint failed screening.
5. Whether Crist's motion to stay the action for 180 days should be granted.

Disposition

other