Summary
The United States District Court for the Eastern District of California screened a state prisoner’s second amended complaint under 28 U.S.C. § 1915A. The magistrate judge recommended allowing Eighth Amendment denial-of-medical-care claims against defendants Lehil and Bailey to proceed and dismissing the remaining claims, including the alleged discrimination claim.
Topics
Practice areas
Questions Presented
- Whether the second amended complaint stated actionable claims for purposes of mandatory screening under 28 U.S.C. § 1915A.
- Whether plaintiff's allegations supported an Eighth Amendment denial-of-medical-care claim against defendants Lehil and Bailey.
- Whether plaintiff's allegation of discrimination based on transgender status stated a claim where the complaint identified no supporting facts.
Holdings
- A prisoner complaint seeking relief against governmental entities or employees must be screened, and claims that are frivolous or malicious, fail to state a claim, or seek monetary relief from an immune defendant must be dismissed.
- The claims for denial of medical care in violation of the Eighth Amendment against defendants Lehil and Bailey may proceed past screening.
- The transgender-discrimination claims should be dismissed because plaintiff alleged no facts reasonably suggesting that defendants discriminated against him because he is transgender.
Key quotations
“The court is required to screen complaints brought by prisoners seeking relief against a governmental entity or officer or employee of a governmental entity.” (at 1)
“Having conducted the required screening, the court finds that plaintiff should be permitted to proceed on claims for denial of medical care in violation of the Eighth Amendment against defendants Lehil and Bailey.” (at 1)
Factual background
Plaintiff is a state prisoner who sued CDCR employees under 42 U.S.C. § 1983. He alleged denial of medical care and also alleged that defendants discriminated against him because he is transgender. The court found that the medical-care allegations against Lehil and Bailey could proceed, but that the discrimination allegation lacked facts reasonably suggesting discrimination.
Procedural history
Plaintiff filed a second amended complaint against employees of the California Department of Corrections and Rehabilitation. The matter was referred to the magistrate judge under Local Rule 302 and 28 U.S.C. § 636(b)(1). Following mandatory prisoner-complaint screening, the magistrate judge recommended that the medical-care claims against defendants Lehil and Bailey proceed and that all other claims be dismissed, subject to the parties' opportunity to object.
Remand instructions
The findings and recommendations were submitted to the assigned United States District Judge for review under 28 U.S.C. § 636(b)(1). Plaintiff was given fourteen days after service to file written objections. The document recommends dismissal of all claims other than the Eighth Amendment medical-care claims against Lehil and Bailey.