(PC) Graves v. Magrini, 2:20-cv-00596

Plaintiff Brian Graves, a Shasta County Jail inmate, proceeds pro se under 42 U.S.C. § 1983 challenging the jail’s electronic administrative appeals system.
Graves contends the electronic system provides no written documentation, leaving him without exhibits to support civil-rights and habeas filings.
The court previously screened and dismissed Graves’s original complaint for failure to state a claim and now screens his amended complaint under 28 U.S.C. § 1915A.
The court finds no constitutional requirement that a prison operate a particular grievance system or provide paper copies to inmates.
The court also finds Graves fails to allege the requisite actual injury to support an access-to-courts claim (i.e., specific facts showing litigation efforts were hindered or an actionable claim was lost).
The amended complaint is dismissed with leave to amend within 30 days; plaintiff is warned not to add unrelated claims and to file a complete, standalone amended complaint per local rules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jail's electronic grievance system violates constitutional rights	Graves says lack of written grievances and exhibits denies him fair access to administrative remedies and harms his legal cases	Jail asserts no constitutional right to any particular grievance procedure or form of recordkeeping	Court: No constitutional entitlement to a specific grievance system; claim fails
Whether the system constitutes denial of access to courts	Graves contends absence of paper exhibits hindered his ability to bring civil-rights or habeas claims	Jail argues Graves did not allege specific, actual injury to his litigation efforts	Court: Access-to-courts claim dismissed for failure to allege actual injury per governing precedents
Whether plaintiff may add new or unrelated claims in an amended complaint	Graves may attempt to expand or change claims in amendment	Court cites rule prohibiting unrelated claims in one complaint	Court: Reminder that amended complaint must not change nature of suit or join unrelated claims
Whether leave to amend should be granted and procedural requirements	Graves given opportunity to correct pleading deficiencies	Defendant not contesting leave to amend in order	Court: Dismissed with leave to amend within 30 days; must file complete amended complaint complying with local rules

Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) (no constitutional right to a specific prison grievance procedure)
Buckley v. Barlow, 997 F.2d 494 (8th Cir. 1993) (grievance procedures are not constitutionally mandated)
Lewis v. Casey, 518 U.S. 343 (1996) (access-to-courts claim requires showing actual injury to litigation)
Christopher v. Harbury, 536 U.S. 403 (2002) (clarifies actual-injury requirement for access-to-courts claims)
George v. Smith, 507 F.3d 605 (7th Cir. 2007) (prohibits combining unrelated claims against different defendants in one complaint)
Forsyth v. Humana, 114 F.3d 1467 (9th Cir. 1997) (amended complaint supersedes the original complaint)
Loux v. Rhay, 375 F.2d 55 (9th Cir. 1967) (same principle that amended pleading replaces prior pleading)