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Bryant v. Guzman
3:25-cv-00724
S.D. Cal.
Jul 10, 2025
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Background

  • Plaintiff Shannon Andre Bryant, a state prisoner, filed a pro se civil rights complaint under 42 U.S.C. § 1983.
  • Bryant alleged he was injured (sprained ankle) after stepping on a crack while playing basketball due to negligent maintenance at Centinela State Prison.
  • The Court screened the complaint after granting in forma pauperis (IFP) status, finding the allegations only amounted to negligence and did not meet the constitutional standard for deliberate indifference.
  • Bryant was given an opportunity to amend his complaint to satisfy the legal standard but did not do so by the court's deadline.
  • Bryant filed a second IFP motion, which was denied as moot since he already had IFP status.
  • The Court dismissed the case without prejudice for failure to state a claim and failure to prosecute.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether negligent maintenance amounts to a § 1983 claim Defendants were negligent; injury resulted Not stated, but arguing no deliberate indifference Negligence alone insufficient; no claim stated
Whether in forma pauperis status warranted again Sought to proceed IFP a second time N/A Second IFP motion moot
Whether dismissal is appropriate for failure to amend Not expressly argued N/A Dismissal warranted for failure to state a claim & prosecute

Key Cases Cited

  • Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference under the Eighth Amendment requires more than negligence, requiring a culpable state of mind)
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Case Details

Case Name: Bryant v. Guzman
Court Name: District Court, S.D. California
Date Published: Jul 10, 2025
Docket Number: 3:25-cv-00724
Court Abbreviation: S.D. Cal.