(PC) Ackerson v. Elliott, 2:21-cv-02205-WBS-KJN

Plaintiff Elton Ackerson, a former county jail inmate and current state prisoner, is proceeding pro se and in forma pauperis in this civil rights lawsuit.
The central incident occurred on January 26, 2021, when Ackerson was a pretrial detainee.
Plaintiff’s claims were initially screened and found to state potentially cognizable Eighth Amendment violations.
Defendants moved for summary judgment, arguing plaintiff’s rights were not violated under the Eighth Amendment.
Upon reviewing the record, the Court determined that the proper constitutional basis was the Fourteenth Amendment, not the Eighth, given Ackerson’s pretrial detainee status.
The Court vacated the original screening order's basis and the pending summary judgment motion, granting defendants sixty days to refile under the correct legal standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper constitutional standard	Claims should proceed (substantive)	Cited Eighth Amendment standards	Fourteenth Amendment applies for pretrial detainees
Validity of screening order standard	Seeks relief for violation	Relied on prior Eighth Amendment finding	Screening order must be modified for Fourteenth Amendment
Timeliness/procedural posture	N/A	Relied on incorrect legal standard	Summary judgment motion vacated, may be refiled
Consideration of new evidence/standards	N/A	Based on previously applied standards	Court recognizes need for review under proper standards

City of Los Angeles v. Santa Monica Baykeeper, 254 F.3d 882 (9th Cir. 2001) (court’s inherent authority to reconsider, rescind, or modify interlocutory orders)
Christianson v. Colt Indus. Operating Corp., 486 U.S. 800 (1988) (discussing standards for revisiting prior rulings)
Arizona v. California, 460 U.S. 605 (1983) (reconsideration only for manifest injustice or clear error)
Castro v. County of Los Angeles, 833 F.3d 1060 (9th Cir. 2016) (objective standard for excessive force under Fourteenth Amendment for pretrial detainees)