(PC) Lipsey v. Hand-Ronga, 1:17-cv-01704

Background

Plaintiff Christopher Lipsey, Jr., a state prisoner proceeding pro se and in forma pauperis, filed this 42 U.S.C. § 1983 action on December 19, 2017; the complaint is pending screening under 28 U.S.C. § 1915A.
On January 8, 2018, Lipsey moved for preliminary injunctive relief seeking a court order to: house him permanently in a single cell, grant full privileges wherever housed, prohibit placement on a Sensitive Needs Yard, prevent disclosure of the reason for single-celling, and enjoin retaliation tied to the injunction.
The underlying merits claims in the case challenge events from 2017 and allege due process violations, failure to protect, failure to train, mail interference, and being wrongly labeled a sex offender.
The requested injunction seeks prospective relief regarding Lipsey’s present and future housing and prison conditions at Corcoran State Prison.
The magistrate judge found the requested relief would not remedy the claims currently before the court and therefore concluded the court lacks jurisdiction to grant the requested injunction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff is entitled to a preliminary injunction ordering permanent single-cell housing and related relief	Lipsey seeks immediate and prospective orders to control his housing, privileges, placement off SNY, nondisclosure of reasons, and an anti-retaliation bar	Prison officials implicitly argue the injunction seeks prospective relief unrelated to the claims and beyond the court’s power over persons/claims before it	Denied: court lacks jurisdiction because the requested prospective relief would not remedy the existing claims in this action
Whether the preliminary injunction standard is met	Lipsey contends irreparable harm and entitlement justify injunctive relief	Defendants assert the injunction is not narrowly tailored or necessary to remedy the alleged 2017 violations	Denied: preliminary injunction not justified and relief would not correct the federal rights asserted
Whether the court may issue relief affecting parties/conditions not before the court	Lipsey requests orders directing future prison conduct affecting ongoing housing placement	Defendants argue federal courts need an actual case or controversy and personal jurisdiction over parties/conditions before issuing injunctions	Denied: court must have an actual case or controversy and cannot determine rights of persons not before it
Applicability of PLRA limits on prospective relief	Lipsey’s requested broad, ongoing directives to prison staff	Defendants rely on PLRA requirement that relief be narrowly drawn and least intrusive	Denied: requested relief would be prospective and is not permitted absent showing it remedies the claim and complies with PLRA constraints

Key Cases Cited

Winter v. Natural Resources Defense Council, 555 U.S. 7 (2008) (establishes standard for preliminary injunctions)
City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (federal courts require an actual case or controversy for injunctive relief)
Valley Forge Christian Coll. v. Americans United for Separation of Church and State, 454 U.S. 464 (1982) (standing and case-or-controversy limits on equitable relief)
Zepeda v. United States Immigration Service, 753 F.2d 719 (9th Cir. 1985) (injunctive relief limited to rights of persons before the court)