(PC) Gaines v. CA Dept. of Corrections, 1:15-cv-00587

Background

Plaintiff Thurman Gaines, a pro se California state prisoner with multiple disabilities (degenerative lumbar disease, arthritis, hypertension, Hepatitis-C, and a learning disability), alleges defendants failed to accommodate him with lower-bunk/lower-tier housing.
Gaines suffered two falls (June 30 and July 22, 2014) after not being placed on lower-bunk/lower-tier status and seeks damages, injunctive, and declaratory relief under 42 U.S.C. § 1983 and Title II of the ADA.
Defendants named include CDCR, medical staff (PA Byers, Drs. Zamora, Horowitz, Rudas, RN Cornell) and correctional officers (Greenwall, Mayberry). Claims asserted against individuals in both official and individual capacities.
Court screened the complaint under 28 U.S.C. § 1915A and found the pleading narrative, conclusory, and lacking factual nexus between many defendants’ actions and Gaines’s injuries; some claims also implicated Eleventh Amendment immunity and exhaustion requirements.
Court dismissed claims against RN Cornell, Greenwall, and Mayberry without leave to amend; dismissed claims against CDCR, Dr. Zamora, Dr. Horowitz, and Dr. Rudas with leave to amend; allowed potential amendment on ADA/§1983 medical claims subject to exhaustion and causation deficiencies.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Class certification	Gaines seeks to represent similarly situated prisoners	Pro se plaintiff cannot fairly or adequately represent a class	Court declined class certification
Official-capacity §1983 claims / Eleventh Amendment	Seeks money and injunctive relief from state officials	State and officials in official capacity immune from §1983 monetary damages	Monetary §1983 claims against officials in official capacity dismissed (Eleventh Amendment); prospective relief moot because plaintiff already has a chrono for lower bunk
ADA Title II liability against state/officials	CDCR and officials violated Title II by denying accommodations	Eleventh Amendment bars some suits, but Title II permits official-capacity injunctive relief; plaintiff must show exclusion from services/activities	ADA claim dismissed without prejudice; leave to amend because current facts do not plausibly show exclusion from major life activities beyond recuperation limits
Eighth Amendment / deliberate indifference and causation; exhaustion	Medical and custody staff were deliberately indifferent to serious medical needs and failed to secure safe housing, causing two falls	Many defendants either lacked knowledge, lacked authority to change housing, or had only supervisory/ministerial roles; exhaustion of admin remedies may be incomplete	Claims against Greenwall/Mayberry and RN Cornell dismissed without leave to amend for lack of causal link; claims against Byers, Zamora, Horowitz, Rudas dismissed with leave to amend to plead specific facts (knowledge, timing, causation) and to address exhaustion

Key Cases Cited

Will v. Mich. Dep’t of State Police, 491 U.S. 58 (Eleventh Amendment bars suits for damages against states and arms of the state under § 1983)
Kentucky v. Graham, 473 U.S. 159 (official-capacity suits are suits against the state)
Ex parte Young, 209 U.S. 123 (permits prospective injunctive relief against state officials despite Eleventh Amendment)
Tennessee v. Lane, 541 U.S. 509 (Title II of the ADA can validly abrogate state immunity for certain federal rights)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard requires more than conclusory allegations)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (complaint must plead facts plausibly showing entitlement to relief)
Woodford v. Ngo, 548 U.S. 81 (exhaustion requirement under the PLRA is mandatory)
Booth v. Churner, 532 U.S. 731 (administrative remedies must be exhausted even if relief is unavailable through them)
Jones v. Bock, 549 U.S. 199 (prisoner not required to plead exhaustion; exhaustion is an affirmative defense)
Porter v. Nussle, 534 U.S. 516 (exhaustion requirement applies to all inmate suits about prison life)