Reese v. CDCR, et al.

Summary

The United States District Court for the Eastern District of California screens Plaintiff Keith Ryan Reese’s first amended prisoner civil rights complaint under 28 U.S.C. § 1915A. The court finds potentially cognizable Equal Protection claims against Hennigan and Skelton, while concluding that the claim against warden Schultz impermissibly relies on respondeat superior and should be dismissed. The court also directs termination of CDCR as a named defendant and recommends dismissal of Schultz.

Holdings

1. The first amended complaint plausibly stated potentially cognizable claims against Hennigan and Skelton for violations of Reese's rights under the Equal Protection Clause based on alleged racial discrimination.
2. The claim against Schultz failed because the allegation that he allowed his employees to discriminate against Reese stated only a respondeat superior theory, which is not cognizable under § 1983, and did not specifically allege Schultz's own participation, direction, deficient policy, or failure to prevent a known constitutional violation.

Questions Presented

1. Whether the first amended complaint plausibly stated equal-protection claims against Hennigan and Skelton based on alleged racial discrimination and racial slurs.
2. Whether the amended complaint stated a cognizable 42 U.S.C. § 1983 claim against supervisory defendant Schultz based only on allegations that he allowed employees to discriminate against Reese.
3. Whether CDCR should remain a named defendant after it was omitted from the first amended complaint.

Disposition

other