Harris v. Director of C.D.C.R., 4:18-cv-01114

Plaintiff Ernest S. Harris, a California state prisoner, filed a pro se § 1983 civil rights complaint while housed at California State Prison–Corcoran.
He sued the Director of CDCR and Pelican Bay State Prison (PBSP) officials, alleging three main harms: (1) PBSP/CDCR failed to hire African American employees, causing racially biased altercations; (2) women face housing discrimination because they cannot be housed in maximum security facilities like men; (3) CDCR/PBSP denied him the right to vote by failing to provide registration materials or ballots.
The Court screened the complaint under 28 U.S.C. § 1915A and applied the plausibility and standing standards from Twombly and Lujan.
The Court concluded the first two claims primarily seek relief for injuries to third parties (unhired African Americans and female inmates) and therefore that Harris lacks standing to pursue them.
The Court also held that the asserted harms do not establish a cognizable constitutional violation (no constitutional right to racially matched guards or to placement of women in maximum security) and that denial-of-vote claim is foreclosed by California law disqualifying incarcerated felons from voting.
The action was dismissed with prejudice as amendment would be futile; judgment to be entered and case closed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to hire African American staff	PBSP/CDCR’s lack of African American employees caused racially biased altercations and harmed Harris	Claims concern third-party employment decisions and do not show a personal constitutional violation	Dismissed for lack of standing and no cognizable constitutional claim
Gender-based housing discrimination	Female inmates are discriminated against because they are not housed in the same maximum security facilities as men	Claim seeks relief for third-party inmates and does not allege Harris’s own constitutional injury	Dismissed for lack of standing; not a cognizable personal claim
Denial of voting rights	Defendants failed to provide registration forms, mail-in ballots, or voting booths, denying Harris the right to vote	California law disqualifies incarcerated felons from voting; defendants’ conduct had no effect on voting eligibility	Dismissed as meritless under state disqualification law

Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (9th Cir. 1988) (pro se pleadings must be liberally construed)
Erickson v. Pardus, 551 U.S. 89 (2007) (Rule 8 requires short and plain statement; pro se pleadings are held to less stringent standards)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must contain sufficient factual matter to state a plausible claim)
West v. Atkins, 487 U.S. 42 (1988) (elements of a § 1983 claim: federal right and state action)
Allee v. Medrano, 416 U.S. 802 (1974) (plaintiff cannot assert rights of third parties to establish standing)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury in fact, causation, and redressability)
Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment requires prison officials take reasonable measures to guarantee inmate safety)
Carrico v. City and Cnty. of San Francisco, 656 F.3d 1002 (9th Cir. 2011) (leave to amend may be denied when amendment would be futile)