Samuel Samson Guzman v. R. Valdez, M. Jimenez, V. Cuevas, and Scott Frauenheim

Summary

The United States District Court for the Eastern District of California partially adopts and partially declines to adopt a magistrate judge’s findings and recommendations in Samuel Samson Guzman’s 42 U.S.C. § 1983 action. The court dismisses the Eighth Amendment claim, permits the First Amendment retaliation claim against defendants R. Valdez and M. Jimenez to proceed, and refers the Fourteenth Amendment due process claim back to the magistrate judge for further consideration as to each defendant. The claims arise from an allegedly retaliatory rules violation report concerning an STG-related symbol and alleged lack of notice that the symbol was prohibited.

Holdings

1. The third amended complaint plausibly stated a First Amendment retaliation claim against Valdez and Jimenez. Although issuing an RVR for STG behavior may ordinarily advance a legitimate correctional goal, the alleged suspicious timing, asserted retaliatory motive, and alleged inconsistent use of disciplinary measures were sufficient at the pleading stage to plausibly show that the action did not reasonably advance a legitimate correctional goal.
2. The third amended complaint plausibly stated a procedural due process claim based on the alleged absence of fair notice that a butterfly was a newly certified STG symbol. The matter was referred back to the magistrate judge for further findings concerning whether the claim was sufficiently pleaded against each defendant.
3. The Eighth Amendment claim was dismissed for failure to state a claim because the third amended complaint alleged no facts supporting such a violation.

Questions Presented

1. Whether the third amended complaint plausibly stated a First Amendment retaliation claim based on defendants' issuance of an STG-related RVR after Guzman filed a grievance.
2. Whether the third amended complaint plausibly stated a Fourteenth Amendment procedural due process claim based on the alleged lack of fair notice that a butterfly had become a prohibited STG symbol.
3. Whether the third amended complaint stated an Eighth Amendment claim.

Disposition

other