North v. Salazar

Summary

The United States District Court for the Southern District of California grants Demaruea North leave to proceed in forma pauperis but dismisses his prisoner civil-rights complaint for failure to state a claim under 28 U.S.C. §§ 1915(e)(2) and 1915A(b). The complaint alleges that prison officials failed to provide a surgical or ADA mattress after spinal surgery, resulting in alleged constitutional violations involving cruel and unusual punishment, due process, and equal protection. The court also denies as moot North’s motion to change his jury demand.

Holdings

1. A district court must sua sponte dismiss a prisoner's complaint, or any portion of it, that is frivolous, malicious, fails to state a claim, or seeks damages from an immune defendant; the screening standard is the same as Rule 12(b)(6).
2. A supervisor may not be held liable under § 1983 solely because of a subordinate's conduct or the supervisor's position; the plaintiff must plead personal involvement or a sufficient causal connection between the supervisor's wrongful conduct and the constitutional violation.
3. The denial, rejection, or inadequate handling of a prison grievance, without more, does not violate the Due Process Clause because prisoners have no constitutional entitlement to a prison grievance procedure.
4. A viable Equal Protection Clause claim requires facts plausibly showing that each defendant intentionally discriminated against the plaintiff because of membership in a protected class; a conclusory allegation that defendants discriminated against Black prisoners is insufficient.
5. The complaint did not plausibly state an Eighth Amendment claim because a five-day deprivation of a mattress was not, on the pleaded facts, an objectively sufficiently serious deprivation, and the complaint did not show that Salazar knew of and disregarded a substantial risk of serious harm.
6. A pro se plaintiff should ordinarily be given leave to amend unless it is clear that the pleading's deficiencies cannot be cured by additional facts.

Questions Presented

1. Whether the complaint stated a plausible § 1983 claim against the supervisory defendants based on their alleged supervisory, hiring, and grievance-review roles.
2. Whether the alleged denial or handling of North's prison grievance stated a due-process claim.
3. Whether the complaint plausibly alleged intentional race- or disability-based discrimination under the Equal Protection Clause.
4. Whether the five-day deprivation of a requested surgical or ADA mattress plausibly stated an Eighth Amendment cruel-and-unusual-punishment claim.
5. Whether the complaint's conclusory law-library and RICO allegations stated cognizable claims.

Disposition

dismissed