(PC) Coleman v. Davis
2:15-cv-01434
E.D. Cal.Dec 8, 2017Background
- Plaintiff Saahdi Coleman, a state prisoner proceeding pro se and in forma pauperis, filed a § 1983 action alleging denial of access to the courts and retaliation related to law-library services.
- After an initial § 1915A dismissal recommendation, Coleman filed a timely amended complaint (May 12, 2017); the court withdrew the prior recommendation and screened the amended pleading.
- Coleman alleges Law Librarian C. Davis gave poor legal advice (urging state-court filing), withheld materials, shortened library visits, and later filed a false rules-violation report; he notified Wardens Barnes and Foulk of library deficiencies but they took no action.
- Coleman claims Davis’s advice led to a federal civil-rights case being dismissed as res judicata; he also alleges a pattern of retaliatory conduct following his administrative complaints about Davis.
- The court concluded the access-to-courts claim against Davis, Barnes, and Foulk fails for lack of an actual-injury/active-interference showing and recommended dismissal without leave to amend as futile.
- The court found sufficient facts to proceed on a First Amendment retaliation claim against Davis, ordered service steps, and gave Coleman instructions and a deadline to return service forms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Access to courts — denial of legal materials/advice | Coleman: Davis and wardens deprived him of substantive legal materials and misadvised him to file in state court, causing dismissal on res judicata grounds | Davis/Wardens: Denial rests at most on negligence or nonaction; no active interference and no actual injury affecting a non-frivolous legal claim | Dismissed: Access claim fails — poor advice/negligence and wardens' inaction did not show actual injury or active interference; dismiss without leave to amend |
| Retaliation for filing grievances | Coleman: After complaining about Davis, she curtailed visits, denied copies/materials, and filed a false rules violation report to punish him | Davis: (Implicit) Actions were not retaliatory or did not rise to constitutional violation | Proceed: Allegations sufficiently state a First Amendment retaliation claim against Davis; case will proceed as to that claim |
Key Cases Cited
- Silva v. Di Vittorio, 658 F.3d 1090 (9th Cir. 2011) (prison officials need not provide affirmative assistance beyond pleading stage but may not actively interfere with litigation)
- Lewis v. Casey, 518 U.S. 343 (U.S. 1996) (access-to-courts claim requires showing of actual injury to litigation efforts)
- Christopher v. Harbury, 536 U.S. 403 (U.S. 2002) (clarifies the actual-injury requirement and nexus to a nonfrivolous claim)
- Plumeau v. School Dist. #40, 130 F.3d 432 (9th Cir. 1997) (denial of leave to amend appropriate when further amendment would be futile)