(PC) James v. Sacramento County Sheriff Dept.
2:23-cv-00853
E.D. Cal.Jul 7, 2025Background
- Ronald Eugene James, a pro se prisoner, filed a civil rights suit under 42 U.S.C. § 1983 against Sacramento County officials.
- James filed two motions for injunctive relief: (1) a request to be transferred from CDCR custody to Sacramento County Main Jail, and (2) a request that unnamed officials provide him with legal envelopes at his current facility.
- The court noted that CDCR officials and unnamed individuals were not parties to the case, precluding relief against them.
- The court applied federal standards governing injunctions, emphasizing the need for a strong factual and legal showing, especially in the context of mandatory injunctions.
- No nexus was established between the requested relief and the underlying First Amendment retaliation or Eighth Amendment deliberate indifference claims.
- The court issued findings and recommendations to deny both motions for injunctive relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Injunction to transfer to Sacramento County Jail | James requested a transfer but provided no factual or legal support | Not fully briefed; court noted non-parties as target | Denied; cannot grant relief against non-parties and no nexus shown |
| Injunction for provision of legal envelopes | James requested legal envelopes from unnamed officials | Not fully briefed; court noted non-parties as target | Denied; cannot grant relief against non-parties; no irreparable harm or nexus shown |
Key Cases Cited
- Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7 (establishes the four-part test for preliminary injunctions and emphasizes need for likelihood of irreparable injury)
- Stormans, Inc. v. Selecky, 586 F.3d 1109 (applies the Winter standard in the Ninth Circuit for injunctive relief)
- Garcia v. Google, Inc., 786 F.3d 733 (mandatory injunctions require a heightened standard)
- Zenith Radio Corp. v. Hazeltine Research, Inc., 395 U.S. 100 (court cannot issue injunctions against non-parties)
- Prieser v. Newkirk, 422 U.S. 395 (prisoner’s transfer renders injunctive relief regarding conditions of confinement at previous location moot)