(PC) Littleton v. Montiez
2:22-cv-00700-KJM-KJN
E.D. Cal.Jun 3, 2022Background
- Pro se county-jail inmate Michael Littleton filed a 42 U.S.C. § 1983 complaint and was granted in forma pauperis status; the court assessed the statutory filing fee and initial partial payment under 28 U.S.C. § 1915(b).
- Littleton asserted three claims: (1) four bail bond agents and Act-Fast Bail Bonds forged documents and took his money; (2) a broad "laundry list" of jail conditions and alleged failures to respond to medical and safety needs at Sacramento County Jail; and (3) a medical/food-related claim that Aramark food caused a burning sensation, breathing problems, and high blood pressure.
- The complaint named individual bond agents (Mark Montiez, Janea Herrera, Chris Moody, James Montiez) and added Act-Fast Bail Bonds and Aramark in the caption; the complaint otherwise lacked specific allegations tying individual jail officials to the claimed deprivations.
- The court screened the complaint under 28 U.S.C. § 1915A, applying Rule 8 and the § 1983 requirement that defendants act under color of state law and be personally involved in alleged deprivations.
- The court dismissed claim one (bond agents/Act-Fast) without leave to amend because bail bond agents are private actors not acting under color of state law for § 1983 purposes; claims two and three were dismissed for failure to plead specific, individualized facts but plaintiff was granted leave to amend as to claims two and three.
- The court instructed that any amended complaint must be complete, identify specific defendants, allege facts showing each defendant’s personal involvement, and comply with the Federal Rules and Local Rule 220; failure to amend could result in dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether bail bond agents and Act-Fast are state actors under § 1983 | Littleton alleges bond agents forged documents and deprived him of money, implying § 1983 liability | Bond agents/Act-Fast are private actors and did not act under color of state law | Dismissed without leave: bail bond agents/Act-Fast are not state actors for § 1983 (claim one) |
| Whether the jail-conditions/medical allegations state a § 1983 claim against identifiable individuals | Littleton alleges multiple deprivations (no grievances, inadequate care, unsanitary cells, ignored emergency calls, slips/seizures) | Defendants not identified; allegations are generalized and do not show personal involvement or deliberate indifference by named individuals | Dismissed (claim two) for failure to allege individual culpability and for noncompliance with Rule 8; leave to amend granted |
| Whether Aramark/food claim states an Eighth Amendment conditions-of-confinement claim | Littleton alleges food caused burning, breathing problems, and high blood pressure and requests testing/money damages | Aramark is a private contractor and complaint lacks facts showing food deprivation rises to constitutional level or that Aramark acted under color of state law | Claim dismissed as deficient; food-complaint likely frivolous if alleging mere smell/seasoning, but leave to amend granted to attempt Eighth Amendment or medical-indifference theory |
| Whether plaintiff may proceed with the complaint as pleaded and how to amend | Littleton seeks money damages and broad relief across disparate claims | Court requires concise, specific allegations tied to each defendant; prohibits shotgun pleading and unrelated claims in one suit | Complaint dismissed in whole; claims 2 and 3 dismissed with leave to amend under Rule 8 and § 1983 pleading standards; claim 1 dismissed without leave |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (frivolous-pleading standard)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Rule 8 pleading standard)
- Erickson v. Pardus, 551 U.S. 89 (liberal construction of pro se complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (personal involvement and pleading requirements)
- West v. Atkins, 487 U.S. 42 (elements of a § 1983 claim)
- Lugar v. Edmondson Oil Co., 457 U.S. 922 (state-action test for private parties)
- Ouzts v. Maryland Nat’l Ins. Co., 505 F.2d 547 (bail bond agents not state actors)
- Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard)
- Estelle v. Gamble, 429 U.S. 97 (medical deliberate indifference under Eighth Amendment)
- Hudson v. McMillian, 503 U.S. 1 (conditions-of-confinement severity requirement)
- Jett v. Penner, 439 F.3d 1091 (Eighth Amendment medical-care analysis)