Jones v. Roberts
5:12-cv-05621
N.D. Cal.May 16, 2013Background
- Jones, a pro se state prisoner, filed an amended §1983 complaint with ADA and RA claims in the Northern District of California.
- Defendants attached Jones's amended complaint to a screening motion; the court granted screening and ordered the clerk to file the amended complaint.
- Jones alleges that Roberts and Robinson ignored ADA accommodations prohibiting him from working with heavy machinery at PIA Textiles.
- Jones received RVRs for disobeying orders and failing to report to work, and was adjudicated guilty, resulting in C-status and loss of privileges.
- Jones sought expungement of the RVRs, but administrative appeals were denied at various levels; additional defendants were named in later filings.
- The court ultimately dismissed several defendants and claims, retaining cognizable ADA/RA issues against Roberts and Robinson for screening and possible dispositive relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ADA/RA claims against Roberts and Robinson are cognizable | Jones alleges Roberts/Robinson ignored ADA docs and discriminated. | Roberts/Robinson contended no viable ADA/RA claim stated against them based on record. | Cognizable ADA/RA claim stated against Roberts and Robinson. |
| Whether equal protection claim survives | Jones asserts invidious discrimination among inmates. | No identifiable class or similarly situated inmates shown by Jones. | DISMISSED without prejudice. |
| Whether due process claim regarding false disciplinary charges state a claim | Seeks removal of false charges from central file. | No constitutional immunity from false charges; due process requires hearing; fabrication alone not a §1983 claim. | DISMISSED without leave to amend. |
| Whether claims against Lacy, Lozano, and Sheffield have constitutional merit | Lacy/Lozano denied expungement; Sheffield reviewed ADA documents. | No constitutional right to a functioning prison appeals system; failure to expunge does not violate due process. | Lacy, Lozano, and Sheffield DISMISSED (Lacy/Lozano with prejudice; Sheffield without prejudice). |
| Whether Doe defendants can be retained or dismissed | Doe defendants should be identified or allowed after discovery. | John Doe defendants are not favored and disclosures are premature. | Doe defendants DISMISSED without prejudice; plaintiff may move to amend after discovery. |
Key Cases Cited
- More v. Farrier, 984 F.2d 269 (8th Cir. 1993) (equal protection requires an identifiable class; no triable issue here)
- Furnace v. Sullivan, 705 F.3d 1021 (9th Cir. 2013) (classify similarly situated inmates for equal protection challenges)
- Sprouse v. Babcock, 870 F.2d 450 (8th Cir. 1989) (no due process right to expungement; false charges alone not a 1983 claim)
- Hanrahan v. Lane, 747 F.2d 1137 (7th Cir. 1984) (due process in disciplinary hearings; fabricated charges not sufficient)
- Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) (no federal constitutional right to an administrative appeal system)
- Gillespie v. Civiletti, 629 F.2d 637 (9th Cir. 1980) (avoidance of Doe defendants; issues with identifying real parties)
- Taylor v. List, 880 F.2d 1040 (9th Cir. 1989) (personal participation required for §1983 liability)
