Summary
The United States District Court for the Eastern District of California screened Michael Castrellon’s pro se prisoner civil-rights complaint under 28 U.S.C. § 1915A. The court granted in forma pauperis status and found cognizable Eighth Amendment claims for failure to protect, deliberate indifference to serious medical needs, and excessive force, while finding other claims and defendants insufficiently pleaded. Plaintiff was given 21 days to elect whether to proceed on the cognizable claims or file an amended complaint.
Topics
Practice areas
Questions Presented
- Whether the complaint stated an Eighth Amendment failure-to-protect claim against Tsvetkov and Waldron.
- Whether the complaint stated an Eighth Amendment deliberate-indifference-to-serious-medical-needs claim against John Does Nos. 1-3.
- Whether the complaint stated an Eighth Amendment excessive-force claim against John Does Nos. 1-3.
- Whether the complaint stated claims against Macomber, Chavez, or Lynch based on official-capacity liability, supervisory liability, or the allegations in the complaint.
- Whether the complaint stated a First Amendment retaliation claim based on an alleged attack motivated by plaintiff's grievance.
- Whether the complaint stated a Fourteenth Amendment equal-protection claim.
Holdings
- At the screening stage, allegations that Tsvetkov and Waldron knowingly allowed and facilitated an unauthorized inmate to enter plaintiff's building and cell adequately stated claims that they were deliberately indifferent to a substantial risk of serious harm.
- The complaint stated a cognizable deliberate-indifference claim against John Doe No. 2, but not against John Does Nos. 1 or 3.
- The complaint stated cognizable excessive-force claims against John Does Nos. 1 and 3, but not John Doe No. 2.
- The complaint failed to state claims for relief against Macomber, Chavez, or Lynch.
- The complaint failed to state a First Amendment retaliation claim.
- The complaint failed to state an equal-protection claim because it did not allege that defendants acted with discriminatory intent based on plaintiff's membership in a protected class.
Key quotations
“whenever prison officials stand accused of using excessive physical force in violation of the Cruel and Unusual Punishments Clause, the core judicial inquiry is… whether force was applied in a good-faith effort to maintain or restore discipline, or maliciously and sadistically to cause harm.” (opinion at 8)
“A supervisor is only liable for the constitutional violations of … subordinates if the supervisor participated in or directed the violations, or knew of the violations and failed to act to prevent them. There is no respondeat superior liability under [§] 1983.” (opinion at 10)
Factual background
Castrellon was incarcerated at California State Prison, Sacramento. During an October 12, 2022 dayroom disturbance, he alleged that a correctional officer ordered him to stand and that another officer shot him in the elbow with a block gun, after which an officer refused his requests for medical attention. He further alleged that on November 29, 2022, officers knowingly allowed inmates to enter his building and cell, where they attacked him, and that an officer fired a launcher round that struck him in the face. He claimed that these events violated the First, Eighth, and Fourteenth Amendments.
Procedural history
Michael Castrellon filed a pro se action under 42 U.S.C. § 1983 and requested leave to proceed in forma pauperis. The court granted the initial in forma pauperis motion, denied a duplicate motion as moot, screened the complaint, found several Eighth Amendment claims cognizable, and found that claims against Macomber, Chavez, and Lynch and the First Amendment retaliation and Fourteenth Amendment equal-protection claims failed to state a claim. The court gave plaintiff 21 days to elect either to proceed on the cognizable claims or file an amended complaint.