Gonzales v. California Department of Corrections
2014 U.S. App. LEXIS 775
9th Cir.
2014

Background

  • Gonzales, a California prisoner, challenged SHU confinement based on gang-validation evidence.
  • IGI tied him to Northern Structure via letters, artwork, an address card, and an informant memo; one piece of evidence failed departmental standards.
  • State habeas petitions contested the evidentiary basis; courts found some evidence sufficient under Madrid v. Gomez and related standards.
  • Gonzales filed § 1983 action alleging First Amendment, due process, retaliation, Equal Protection, and Eighth Amendment claims; district court held claims precluded by claim preclusion.
  • The district court denied standing on the Eighth Amendment debriefing claim; the court dismissed most claims, denied amendment relief, and entered judgment.
  • On appeal, the Ninth Circuit addressed whether California habeas judgments have claim- and/or issue-preclusion effect on § 1983 actions, and standing for debriefing claim.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether California habeas judgments have claim preclusion effect on § 1983 claims Gonzales argues a habeas denial does not bar § 1983 claims for damages. CDC asserts claim preclusion applies to the later civil action. California claim preclusion can bar § 1983 claims arising from the same primary right.
Whether the claims arising from the same confinement actions are-the-same primary right Gonzales contends procedural vs. substantive harms create separate causes of action. The same harm and duties under the same primary right preclude later claims. Same primary right governs; cannot split claims when same harm and duty occurred.
Whether Gonzales's First Amendment, retaliation, and Equal Protection claims survive These are distinct, substantive harms not barred by habeas preclusion. Preclusion bars them as arising from the same underlying actions. Precluded; those claims are barred as to the same underlying action.
Whether Gonzales has standing to challenge the debriefing process Gonzales alleges he would attempt to debrief and faces risk of retaliation; standing exists. Standing requires a real debriefing possibility; past denial suggested no standing. Gonzales has standing to challenge the debriefing process.
Whether the Eighth Amendment debriefing claim should be remanded for amendment District court erred in not allowing amendment to address Eighth Amendment issues. Amendment was contingent on surviving preclusion and standing issues. Remand for reconsideration of the debriefing claim after allowance of amendment.

Key Cases Cited

  • Silverton v. Department of Treasury, 644 F.2d 1341 (9th Cir. 1981) (full and fair hearing for issue preclusion in habeas context)
  • Brodheim v. Cry, 584 F.3d 1262 (9th Cir. 2009) (analyzed claim vs. issue preclusion under California law)
  • Taylor v. Sturgell, 553 U.S. 880 (2008) (explains preclusion principles and related doctrines)
  • Toussaint v. McCarthy, 801 F.2d 1080 (9th Cir. 1986) (Some evidence standard context for due process in confinement)
  • Slater v. Blackwood, 543 P.2d 593 (Cal. 1975) (valid final judgment on merits bars further litigation on same cause)
  • Wulfjen v. Dolton, 151 P.2d 846 (Cal. 1944) (no split of a single cause of action)
  • Younan v. Caruso, 59 Cal. Rptr. 2d 103 (Cal. Ct. App. 1996) (habeas denial doctrine; context not extending to civil actions)
  • Gomez v. Superior Court, 278 P.3d 1168 (Cal. 2012) (summary denial lacks res judicata effect in future proceedings)
  • Rhodes v. Hannigan, 12 F.3d 989 (10th Cir. 1993) (habeas judgments not always preclusive depending on law)
  • Burgos v. Hopkins, 14 F.3d 787 (2d Cir. 1994) (New York habeas does not preclude subsequent civil suits)
  • Allstate Ins. Co. v. Mel Rapton, Inc., 92 Cal. Rptr. 2d 151 (Cal. Ct. App. 2000) (splitting a cause of action not allowed; jurisdictional limits matter)
  • Crowley v. Katleman, 881 P.2d 1083 (Cal. 1994) (primary rights theory definition of same cause of action)
  • Eichman v. Fotomat Corp., 197 Cal. Rptr. 612 (Cal. Ct. App. 1983) (same primary right concept applied)
  • Mycogen Corp. v. Monsanto Co., 51 P.3d 297 (Cal. 2002) (claim preclusion under primary rights theory)
  • Boeken v. Philip Morris USA, Inc., 230 P.3d 342 (Cal. 2010) (same primary right; damages and other relief barred)
  • Madrid v. Gomez, 889 F. Supp. 1146 (N.D. Cal. 1995) (evidentiary basis required for confinement decisions)
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