(PC) Martinez v. Davey
1:16-cv-01658-DAD-JLT
E.D. Cal.Jan 4, 2017Background
- Plaintiff Ricardo Martinez, a former state prisoner proceeding pro se and in forma pauperis, filed a § 1983 complaint alleging denial of adequate medical care, interference with outgoing mail, and assault by officers while housed at Corcoran State Prison.
- Complaint named Warden D. Davey, an unnamed Chief Medical Officer, and multiple John/Jane Does, in individual and official capacities.
- Plaintiff attached ~150 pages of medical requests and records but the body of the complaint contained minimal, conclusory allegations without linking facts to named defendants.
- Plaintiff seeks monetary damages.
- Court screened the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii) and Federal Rule of Civil Procedure 8 and found the pleading deficient.
- Court dismissed the complaint with leave to amend, gave legal guidance on required pleading elements, and set a 30-day deadline and a 20-page limit for the amended complaint (no attachments).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to comply with Rule 8 / failure to state a claim | Martinez alleges multiple constitutional violations but in conclusory, disorganized form and relies on voluminous attachments | Defendants (via court) argue complaint lacks a short, plain statement linking facts to defendants | Complaint dismissed for failure to comply with Rule 8; leave to amend granted |
| Linkage / supervisory liability under § 1983 | Martinez names supervisors (e.g., Warden) and unnamed officials for constitutional deprivations | Supervisors not automatically liable; must be linked by personal acts/knowledge of violations | Court instructs plaintiff must plead specific acts or knowledge for each defendant to state a claim |
| Eleventh Amendment immunity for official-capacity damages | Plaintiff seeks damages against officials in official and individual capacities | State and state agencies immune from suit for money damages in federal court | Court reminds Eleventh Amendment bars money damages claims against state officials in official capacity; personal-capacity claims still possible |
| Eighth & First Amendment claims (medical care, excessive force, mail) | Martinez alleges deliberate indifference to serious medical needs, assault by officers, and outgoing mail interference | Legal standards require (a) serious medical need + deliberate indifference; (b) force must be malicious/sadistic; (c) mail restrictions must further substantial, non-suppressive interest and be no greater than necessary | Court explains governing standards (deliberate indifference; malicious/sadistic test; Procunier/Thornburgh test) and directs plaintiff to plead facts meeting those standards if amending |
Key Cases Cited
- Wilder v. Virginia Hosp. Ass'n, 496 U.S. 498 (1990) (§ 1983 provides remedy for deprivation of federal rights)
- Graham v. Connor, 490 U.S. 386 (1989) (§ 1983 not a source of substantive rights; standard for excessive force under Fourth Amendment principles)
- West v. Atkins, 487 U.S. 42 (1988) (action under color of state law requirement for § 1983)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard; conclusory allegations insufficient)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (no respondeat superior liability for municipalities and supervisors without policy or direct action)
- Hafer v. Melo, 502 U.S. 21 (1991) (personal-capacity suits for damages allowed against state officials)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard for Eighth Amendment)
- Estelle v. Gamble, 429 U.S. 97 (1976) (medical care claims under Eighth Amendment; negligence not sufficient)
- Hudson v. McMillian, 503 U.S. 1 (1992) (excessive force standard: malicious and sadistic)
- Whitley v. Albers, 475 U.S. 312 (1986) (excessive force factors and deference to prison officials)
- Procunier v. Martinez, 416 U.S. 396 (1974) (mail restriction test for outgoing prisoner mail)
- Thornburgh v. Abbott, 490 U.S. 401 (1989) (limits on Procunier test as applied to incoming mail)
- Jett v. Penner, 439 F.3d 1091 (9th Cir. 2006) (elements for medical indifference claim)
- McGuckin v. Smith, 974 F.2d 1050 (9th Cir. 1992) (indicators of serious medical need and deliberate indifference)
- Jones v. Williams, 297 F.3d 930 (9th Cir. 2002) (personal participation requirement for individual-capacity § 1983 claims)