In re CIM-SQ Transfer Cases

Summary

The United States District Court for the Northern District of California screens a prisoner civil-rights complaint arising from the May 2020 transfer of inmates from California Institution for Men to San Quentin State Prison during the COVID-19 pandemic. The court dismisses the California Department of Corrections and Rehabilitation as immune from damages claims, finds a cognizable Eighth Amendment deliberate-indifference claim against former warden Ronald Broomfield, orders service, and keeps the case stayed for purposes other than service.

Holdings

1. The California Department of Corrections and Rehabilitation is immune from a § 1983 damages action because it is a state agency and the action operates as a suit against the State.
2. Liberally construed, the allegations stated a plausible Eighth Amendment claim for deliberate indifference to plaintiff's health and safety against Broomfield.
3. The complaint survived screening as to Broomfield because it alleged sufficient facts to state a plausible claim, while the claim against CDCR was dismissed as barred by immunity.

Questions Presented

1. Whether the damages claims against the California Department of Corrections and Rehabilitation were barred by Eleventh Amendment sovereign immunity.
2. Whether the complaint plausibly alleged an Eighth Amendment deliberate-indifference claim against Ronald Broomfield.
3. Whether the complaint should be screened under 28 U.S.C. § 1915A and served on the surviving defendant.

Disposition

other