Chaz Jamar MacFalling v. D. Nettleton, 2:17-cv-02399

Background

Pro se prisoner MacFalling sued several CMC correctional officers and Acting Associate Warden Core under 42 U.S.C. § 1983 for events on Sept. 22, 2016: officers removed a “Black Lives Matter” placard taped to his back; he refused an order to remove it; was searched, handcuffed, put in a small cell (~3' x 3') for ~3.5 hours, and later placed in administrative segregation and found guilty on an RVR with loss of credits.
Alleged injuries: overly tight handcuffs causing pain, cuts, abrasions, swollen hands; denied medical assistance; forced to hold urine for over an hour; verbal taunts and threats by officers; pepper spray/baton threats during search.
Complaint pleaded mixed claims together (retaliation, deliberate indifference, conditions of confinement, denial of medical care, and challenge to disciplinary sanction) and named defendants in individual and official capacities.
Court screened the complaint under the PLRA and Rule 8 and found the pleading both noncompliant with Rule 8 (not a short, plain statement per defendant/claim) and factually insufficient to state plausible First or Eighth Amendment claims.
Court dismissed the complaint with leave to amend, explaining Eleventh Amendment bars official-capacity damages, describing pleading deficiencies for retaliation, Eighth Amendment (force/medical/conditions), supervisory liability, and Heck/Preiser limits on disciplinary-challenge relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eleventh Amendment / official-capacity damages	Seeks monetary damages from CDCR employees in official and individual capacity	CDCR is a state agency immune from § 1983 monetary suits	Official-capacity monetary claims barred by Eleventh Amendment; plaintiff may not seek such damages against CDCR employees in official capacity
Rule 8 pleading sufficiency	Complaint provides facts of events and injuries	Pleading bundles many claims/facts under single counts, lacks concise per-defendant notice	Complaint violates Rule 8; must plead short, plain statements for each claim and defendant; dismissal with leave to amend
First Amendment retaliation	Wearing political placard and refusal to remove was protected expression; adverse acts were retaliatory	Plaintiff’s refusal to obey a direct order is not protected; adverse actions could be discipline to maintain order	Facts insufficient to plausibly show protected conduct motivated adverse acts rather than refusal to obey; retaliation claims inadequately pleaded
Eighth Amendment excessive force / conditions / medical care	Overly tight handcuffs, prolonged confinement in small cage, denial of medical care, threats constituted cruel and unusual punishment	Force may have been used to maintain order; brief deprivations and minor injuries do not meet objective seriousness; verbal harassment not actionable; brief delay in care insufficient	Allegations, as pleaded, insufficient to state plausible Eighth Amendment claims (force/conditions/medical); must plead specific facts and identify responsible defendants if re-pleading
Supervisory liability	Warden Core is named as defendant	Supervisory liability requires individual culpability or a custom/policy showing; respondeat superior insufficient	Complaint fails to allege Core’s personal involvement or facts supporting failure-to-train/custom theory; supervisory claims dismissed absent proper factual allegations
Disciplinary sanction (RVR loss of credits) and remedies	Loss of credits was retaliatory and seeks relief (expungement/monetary)	Challenge to disciplinary loss of credits implicates duration of confinement and is barred in § 1983 unless prior invalidation	Challenges that would invalidate disciplinary sanction or credits must be pursued in habeas or be preceded by invalidation per Heck/Preiser; § 1983 damages barred until discipline invalidated

Key Cases Cited

Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (9th Cir. 1990) (complaint dismissal standards)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to pleading truth; plausibility standard)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility requirement under Rule 8)
Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment excessive force standard)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard)
Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 claims that would imply invalidity of conviction/sentence barred until invalidated)
Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas is sole federal remedy to challenge fact or length of confinement)
Wolff v. McDonnell, 418 U.S. 539 (1974) (procedural protections for prison disciplinary proceedings; limits on § 1983 relief affecting sentence)
Turner v. Safley, 482 U.S. 78 (1987) (prison regulation validity test balancing penological interests)
Watison v. Carter, 668 F.3d 1108 (9th Cir. 2012) (elements of a prisoner retaliation claim)