Kevin Darnell Bryant v. Raybon C. Johnson, 2:20-cv-03459

Background

Plaintiff Kevin Darnell Bryant, a pro se, IFP state prisoner, filed a Section 1983 action after previously winning a civil suit arising at another prison.
After transfer to CSP-LAC, Bryant alleges prison staff threatened him as ‘‘payback,’’ repeatedly arranged or permitted inmate assaults, and confiscated his property.
He alleges specific incidents: multiple beatings observed or directed by officers, false Rule Violation Reports (RVRs) placing him in administrative segregation (Ad‑Seg), and a sexual assault in a gym restroom culminating in a hospital forensic exam that produced a plastic spoon.
Bryant alleges supervisory conspiracy (wardens, deputy warden, ISU officers) to retaliate and to place him in Ad‑Seg on false charges; he served administrative paperwork and was later transferred to another prison.
The magistrate judge screened the Second Amended Complaint (SAC), found it violative of Rule 8 and deficient on several claims, and dismissed the SAC with leave to amend while identifying which claims/defendants are arguably stated and which are not.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 8 pleading sufficiency	SAC contains detailed facts of assaults, threats, false RVRs and seeks relief	SAC fails to identify which defendants are sued for which legal theory or which specific acts	Court: SAC violates Rule 8; dismiss with leave to amend and must plead claims and defendant-specific facts clearly
First Amendment (retaliation)	Bryant alleges staff retaliated for his prior lawsuit by arranging threats/assaults and false discipline	Some defendants (e.g., Asuncion, Cherpin) lack allegations showing retaliatory intent or causation	Court: Some defendants are arguably implicated, but claims against certain defendants fail as pleaded for lack of causal/intent allegations; plaintiff may amend
Eighth Amendment (failure to protect/excessive force)	Officers knowingly set in motion or failed to stop inmate attacks and subjected Bryant to sexual assault	For some officers (Bridgeforth, Cherpin, Puentes) allegations amount only to threats or lack specific acts causing harm	Court: Several Eighth Amendment claims are arguably stated against particular officers, but claims against some defendants fail to state deliberate indifference or direct causation as pleaded
Fourteenth Amendment (due process / equal protection)	False RVRs and denial of witnesses at hearings, and placement in Ad‑Seg deprived liberty and was discriminatory	Placement in Ad‑Seg did not allege atypical, significant hardship; no allegation of discrimination based on protected class or disparate treatment	Court: Due process and equal protection claims not plausibly alleged; no protected liberty interest shown and no discriminatory intent pleaded

Key Cases Cited

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must give fair notice and state plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (conclusory allegations insufficient; individualized allegations required for government officials)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for failure to protect)
Hudson v. McMillian, 503 U.S. 1 (1992) (Eighth Amendment excessive force inquiry: malicious and sadistic v. good-faith discipline)
Wolff v. McDonnell, 418 U.S. 539 (1974) (procedural due process protections in prison disciplinary proceedings)
Sandin v. Conner, 515 U.S. 472 (1995) (liberty interest requires atypical and significant hardship)
Superintendent v. Hill, 472 U.S. 445 (1985) (disciplinary findings must be supported by some evidence)
Watison v. Carter, 668 F.3d 1108 (9th Cir. 2012) (elements of a prisoner retaliation claim)
Lacey v. Maricopa County, 693 F.3d 896 (9th Cir. 2012) (causation principles for §1983 individual liability)
Starr v. Baca, 652 F.3d 1202 (9th Cir. 2011) (supervisory liability requires personal participation or culpable policy/set-in-motion conduct)