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Jones v. Roberts
5:12-cv-05621
N.D. Cal.
May 16, 2013
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Background

  • 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)
Read the full case

Case Details

Case Name: Jones v. Roberts
Court Name: District Court, N.D. California
Date Published: May 16, 2013
Citation: 5:12-cv-05621
Docket Number: 5:12-cv-05621
Court Abbreviation: N.D. Cal.