Jones v. Borla
3:24-cv-07095
N.D. Cal.Apr 14, 2025Background
- Amos Jones, a California inmate, brought a pro se civil rights action under 42 U.S.C. § 1983 against Edward J. Borla, the Acting Warden of the California Training Facility (CTF).
- Jones alleged that Borla failed to provide portable toilets during a 13.5-hour power outage in October 2023, resulting in inoperable, non-flushing toilets in inmates' cells.
- Jones claimed this deprived him of humane conditions, caused nausea and vomiting due to the smell of waste, and was particularly harmful due to his medical need for frequent restroom use.
- Previously, portable toilets had allegedly been provided during other outages, but not on the occasion in question.
- Jones asserted this failure constituted both a violation of his Eighth Amendment rights and negligence under California law.
- The case came before the court for initial screening under 28 U.S.C. § 1915A, which requires dismissal if the complaint fails to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment | Failure to provide portable toilets during outage was cruel and unusual punishment. | (Not presented on screening; court read as failure to show substantial risk of serious harm.) | No plausible Eighth Amendment violation; temporary non-flushing toilet was not severe or prolonged enough. |
| State Law Negligence | Defendant was negligent in not providing portable toilets during outage. | (Not presented; dismissed for lack of supplemental jurisdiction.) | Dismissed without prejudice; no federal jurisdiction. |
| Leave to Amend | Seeks relief for conditions of confinement. | (Not presented) | Denied; amendment would be futile as facts as alleged cannot support Eighth Amendment claim. |
| Supplemental Jurisdiction | Court should hear state law claim with federal action. | (Not presented) | Declined; negligence claim can be brought in state court. |
Key Cases Cited
- Farmer v. Brennan, 511 U.S. 825 (A prison official is liable under the Eighth Amendment only if they know of and disregard a substantial risk of serious harm to an inmate.)
- Johnson v. Lewis, 217 F.3d 726 (The circumstances, nature, and duration of deprivation determine whether a constitutional violation has occurred.)
- Anderson v. County of Kern, 45 F.3d 1310 (Temporary exposure to unsanitary conditions generally does not rise to the level of an Eighth Amendment violation.)
- Hearns v. Terhune, 413 F.3d 1036 (Prolonged unsanitary prison conditions can state an Eighth Amendment claim.)