(PC) Candler v. Baker
2:17-cv-01885
E.D. Cal.Oct 17, 2017Background
- Plaintiff Keith Candler, a prisoner, filed an amended complaint after removal from Sacramento County Superior Court; the court screened it under 28 U.S.C. § 1915A.
- On June 23, 2016, Candler filed a staff complaint accusing defendant Baker of sexual harassment; he alleges subsequent retaliation by multiple defendants.
- Allegations include: defendants Gonzalez, Marquez, and Rashid told his psychiatric provider he was "just playing games" (leading to his attempted suicide); Whitehead made verbal threats and refused transportation to a medical appointment; Baker and Gonzalez forced him to remove clothing and authored a false RVR; multiple defendants denied canteen access.
- The court evaluated claims for First Amendment retaliation, § 1983 conspiracy to retaliate, Eighth Amendment interference with medical care, and Eighth Amendment sexual harassment.
- The court found the amended complaint sufficient to state potentially cognizable claims against Baker, Gonzalez, Rashid, Whitehead, and Marquez, and ordered service on Rashid; it dismissed claims against defendant Palko.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether allegations state First Amendment retaliation | Candler alleges retaliatory acts (threats, false RVR, denial of canteen/transport) after protected staff complaint | Defendants implicitly contest sufficiency (not expressly detailed in order) | Court: Allegations sufficient to state retaliation claims against Baker, Gonzalez, Rashid, Whitehead, Marquez |
| Whether defendants conspired to retaliate in violation of § 1983 | Candler alleges coordinated acts by listed defendants aimed at punishing protected conduct | Defendants dispute not detailed; court screens for plausibility | Court: Allegations sufficient to state § 1983 conspiracy claims against Baker, Gonzalez, Rashid, Whitehead, Marquez |
| Whether interference with medical care rises to Eighth Amendment violation | Candler alleges providers were told he was "playing games," resulting in return to cell and suicide attempt; denial of transport and other obstructions to care | Defendants contest adequacy of allegations (not detailed) | Court: Allegations sufficient to state Eighth Amendment claims for interference with medical care against Gonzalez, Marquez, Rashid, Whitehead |
| Whether sexual harassment by staff alleges Eighth Amendment violation | Candler alleges Baker and Gonzalez forced him to remove clothing in their presence | Defendants likely deny or dispute facts (not detailed) | Court: Allegations sufficient to state Eighth Amendment sexual harassment claims against Baker and Gonzalez |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (legal frivolity/factual baselessness standard for dismissal)
- Franklin v. Murphy, 745 F.2d 1221 (standards for screening § 1915A pleadings)
- Jackson v. Arizona, 885 F.2d 639 (dismissal of indisputably meritless in forma pauperis claims)
- Lopez v. Smith, 203 F.3d 1122 (pleading standards post-Neitzke for pro se civil rights actions)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Rule 8 and plausibility standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (facial plausibility and pleading requirements)
- Hospital Bldg. Co. v. Rex Hosp. Trs., 425 U.S. 738 (accept allegations as true at pleading stage)
- Jenkins v. McKeithen, 395 U.S. 411 (construe pleadings favorably to plaintiff)