Gabriel Magallanes v. N. Sanchez

Summary

The United States District Court for the Eastern District of California recommends dismissing Gabriel Magallanes’s due process challenge to a prison Rules Violation Report with prejudice for failure to state a claim. The court recommends dismissing newly added, unrelated claims without prejudice because they improperly join defendants and claims and fail to satisfy Federal Rule of Civil Procedure 8. The court also recommends closing the case and advises that objections are due within 30 days.

Holdings

1. The First Amended Complaint failed to state a procedural due-process claim because the allegation that Plaintiff was found guilty on 'no evidence' was conclusory and did not allege that any required Wolff procedure was denied or that the record lacked some reliable evidence supporting the finding.
2. The claims concerning housing, mail, medical care, and equal protection were improperly joined with the disciplinary claim because they involved different defendants, different events, and a different prison, and therefore were not part of the same transaction or occurrence or a common question of law or fact.
3. The new allegations failed to satisfy Rule 8(a)(2) because they provided only brief, conclusory assertions about mail, medical care, housing, and equal protection without clearly identifying the claims, defendants' conduct, or supporting facts.

Questions Presented

1. Whether the First Amended Complaint plausibly alleged that the prison disciplinary proceeding violated procedural due process.
2. Whether the new claims against additional defendants were properly joined with the disciplinary claim under Federal Rules of Civil Procedure 18 and 20.
3. Whether the new allegations satisfied Federal Rule of Civil Procedure 8(a)(2)'s requirement of a short and plain statement showing entitlement to relief.
4. Whether further leave to amend should be granted.

Disposition

other