(PC) Davies v. Reynoso
2:24-cv-00485
E.D. Cal.Jul 7, 2025Background
- Plaintiff Thomas Allen Davies, an incarcerated individual, brought a pro se civil rights action under 42 U.S.C. § 1983 against prison officials.
- The case involves alleged wrongful withholding of Davies' property and exposure to toxic chemicals by prison staff.
- Davies moved for injunctive relief, seeking an order compelling prison officials at Valley State Prison (VSP) to release his property and prevent further harm.
- The motion for injunctive relief was filed against unnamed officials at VSP, which is not where the named defendants are employed.
- The named defendants in the underlying complaint are associated with other prisons (Mule Creek State Prison, California Health Care Facility, R.J. Donovan Correctional Center).
- The magistrate judge recommended denying Davies' motion for injunctive relief, referencing jurisdictional and substantive standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Injunctive relief against VSP officials | Davies argues officials at VSP are withholding property and causing harm, warranting court intervention | Relief sought is against non-parties to the case | Court cannot issue injunction against non-parties; motion denied |
| Likelihood of irreparable harm | Claims ongoing injury from withheld property and chemical exposure | No specific defense argument cited, but standards require strong evidence of harm | Plaintiff failed to demonstrate likelihood of irreparable harm |
| Nexus between claims and motion | Argues connection between harms and underlying claims | No specific defense argument cited | No sufficient nexus between claims in complaint and injunctive relief sought |
| Transfer and mootness of injunctive relief | N/A | Relief moot due to transfer to another institution | Motion for injunctive relief moot when plaintiff is transferred away from alleged source of harm |
Key Cases Cited
- Winter v. Natural Resources Defense Council, Inc., 129 S. Ct. 365 (2008) (sets standard for preliminary injunctive relief: likelihood of success on merits and irreparable harm)
- Stormans, Inc. v. Selecky, 586 F.3d 1109 (9th Cir. 2009) (reiterates Winter standard for preliminary injunctions)
- Garcia v. Google, Inc., 786 F.3d 733 (9th Cir. 2015) (mandatory injunctions require particularly demanding burden)
- Zenith Radio Corp. v. Hazeltine Research, Inc., 395 U.S. 100 (1969) (court cannot issue orders against non-parties)
- Prieser v. Newkirk, 422 U.S. 395 (1975) (transfer of prisoner can moot request for injunctive relief with respect to prior facility)
- Johnson v. Moore, 948 F.2d 517 (9th Cir. 1991) (per curiam) (transfer of inmate moots claims for injunctive relief for previous conditions)