Guillory v. Pfeiffer

Summary

The document contains Findings and Recommendations from the United States District Court for the Eastern District of California following screening of Jovan R. Guillory’s second amended 42 U.S.C. § 1983 complaint. The magistrate judge recommends allowing an Eighth Amendment excessive-force claim to proceed against Correctional Officer Alcantar, dismissing the remaining claims, and dismissing defendants Christian Pfeiffer, E. Stark, and N. Montanez. The recommendations were issued with a 14-day objection deadline.

Holdings

1. Liberally construed and accepting its factual allegations as true, the second amended complaint stated a cognizable Eighth Amendment excessive-force claim against Alcantar because it alleged that Alcantar orchestrated the altercation and used force maliciously, unnecessarily, and without a good-faith effort to maintain security.
2. The complaint failed to state claims against Montanez, Stark, or Pfeiffer because it did not adequately allege their personal participation, a causal connection, an unconstitutional policy or custom, or facts supporting a failure-to-train claim.
3. The complaint failed to state a deliberate-indifference claim against any defendant.
4. The complaint failed to state a due-process claim because it did not allege that any of the minimum procedural protections required in a prison disciplinary proceeding were denied, and the record contained some evidence supporting the disciplinary decision.

Questions Presented

1. Whether the second amended complaint stated a cognizable Eighth Amendment excessive-force claim against Alcantar.
2. Whether the complaint stated Eighth Amendment excessive-force or failure-to-train and supervisory-liability claims against Montanez, Stark, or Pfeiffer.
3. Whether the complaint stated an Eighth Amendment deliberate-indifference claim concerning medical care after Guillory’s injuries.
4. Whether the complaint stated a Fourteenth Amendment procedural-due-process claim based on the prison disciplinary proceeding.

Disposition

other