Johnson v. CTF Soledad State Prison
5:16-cv-05548-EJD
N.D. Cal.Sep 28, 2017Background
- Plaintiff Cedric Chester Johnson, a California state prisoner, sued under 42 U.S.C. § 1983 alleging inadequate medical care at Correctional Training Facility–Soledad after defendants refused his request for a “vision impaired vest” and he later fell and was injured.
- The Court screened the original complaint, concluded it failed to plead defendants’ awareness of an excessive risk to plaintiff’s health, and dismissed with leave to amend.
- Plaintiff filed an amended complaint; the Court again dismissed for failing to cure pleading defects but later granted reconsideration after plaintiff clarified the requested item was a vest, not a test.
- Plaintiff filed a second amended complaint (SAC) that largely repeated prior allegations and attached inmate appeals, but did not allege what each defendant did, when, or facts showing deliberate indifference.
- The magistrate judge found the SAC still failed to plead facts plausibly showing defendants acted with the requisite deliberate indifference under the Eighth Amendment and dismissed the case with prejudice as further amendment was unlikely to cure defects.
- Plaintiff had previously consented to magistrate judge jurisdiction and attempted to withdraw consent with the SAC without showing "extraordinary circumstances;" the Court did not accept withdrawal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the SAC states an Eighth Amendment deliberate indifference claim for denial of needed medical equipment (vision-impaired vest) leading to injury | Johnson alleges denial of a vision-impaired vest led to a fall and injury; seeks relief under § 1983 | Defendants (implicitly) lacked awareness of a risk or did not act with deliberate indifference; factual specifics are lacking | The SAC does not plausibly allege deliberate indifference; claim dismissed for failure to state a claim |
| Whether plaintiff sufficiently pleaded who did what and when to establish individual liability under § 1983 | Johnson provided inmate appeals and general allegations | Defendants argue plaintiff failed to identify specific actions by each defendant | Court held plaintiff failed to plead individualized conduct and mental state; dismissal affirmed |
| Whether the Court should piece together claims from exhibits and attachments | Johnson relies on attached appeal records and exhibits to supply facts | Defendants rely on the pleadings’ adequacy; Court refuses to treat exhibits as a cure for deficient pleading | Court declined to read through exhibits to construct a claim; exhibits did not cure pleading defects |
| Whether to allow further leave to amend after multiple dismissals with guidance | Johnson sought to amend after prior dismissals and clarification about the vest | Defendants did not oppose additional amendment in principle but rely on pleading standards | Court denied further leave to amend, finding plaintiff had been given specific guidance but failed to correct deficiencies |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaint must give fair notice of claim)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state a plausible claim for relief)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for prison conditions/medical care)
- West v. Atkins, 487 U.S. 42 (1988) (§ 1983 requires state-action and constitutional violation)
- Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (9th Cir. 1990) (pro se pleadings must be liberally construed)