(PC) Miller v. Jones, 2:19-cv-01697

Plaintiff Bradley James Miller, a civil detainee, was housed at Sacramento County Main Jail for over seven weeks after transfer from Coalinga State Hospital in May 2019.
Miller alleges the jail applied policies to civil detainees that were identical to or more restrictive than those for criminal inmates, affecting clothing, work, leisure, diet, commissary, bedding, and plumbing.
He sued Sheriff Scott Jones and the County of Sacramento under 42 U.S.C. § 1983, claiming the conditions amounted to unconstitutional punishment of a civil detainee.
The court reviewed pleading standards (Twombly/Iqbal) and the § 1915 screening standards for frivolous or legally insufficient claims.
The court found the complaint vague and conclusory, insufficient to show the nature/extent of deprivations or that defendants acted without legitimate, non-punitive justification; it dismissed the complaint but granted leave to amend.
The court granted Miller in forma pauperis status and instructed that any amended complaint must plead specific facts linking each defendant to alleged deprivations and be complete on its face.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller stated a Fourteenth Amendment claim for unconstitutional punishment of a civil detainee	Conditions at the jail were identical or more restrictive than for inmates and therefore punitive	Policies plausibly serve legitimate, non-punitive objectives (security, management); complaint lacks particularized facts	Complaint dismissed for failure to state a claim; leave to amend
Whether Miller alleged an actionable § 1983 claim against named defendants (personal/municipal liability)	Sheriff/County implemented the restrictive policies and are responsible	No specific factual allegations linking named defendants to the alleged deprivations or policy decisions	Court held plaintiff must plead an affirmative link showing each defendant’s involvement; conclusory allegations insufficient
Procedural: In forma pauperis and further pleading requirements	Miller requested IFP and leave to proceed	—	IFP granted; plaintiff given 30 days to file a complete amended complaint complying with Fed. R. Civ. P. and local rules

Neitzke v. Williams, [citation="490 U.S. 319"] (U.S. 1989) (§1915 frivolous-complaint standard).
Bell Atl. Corp. v. Twombly, [citation="550 U.S. 544"] (U.S. 2007) (pleading must state a plausible claim).
Ashcroft v. Iqbal, [citation="556 U.S. 662"] (U.S. 2009) (threadbare recitals and conclusory allegations insufficient).
Jones v. Blanas, [citation="393 F.3d 918"] (9th Cir. 2004) (civil detainee cannot be subjected to conditions amounting to punishment).
Bell v. Wolfish, [citation="441 U.S. 520"] (U.S. 1979) (constitutional limits on punishment for pretrial/civil detainees).
Kingsley v. Hendrickson, [citation="576 U.S. 389"] (U.S. 2015) (objective standard for evaluating pretrial detainee conditions).
Rizzo v. Goode, [citation="423 U.S. 362"] (U.S. 1976) (affirmative link required for §1983 liability).
Ivey v. Bd. of Regents, [citation="673 F.2d 266"] (9th Cir. 1982) (conclusory allegations of official participation insufficient).
Page v. Torrey, [citation="201 F.3d 1136"] (9th Cir. 2000) (civil detainees are not prisoners under the PLRA).
Loux v. Rhay, [citation="375 F.2d 55"] (9th Cir. 1967) (an amended complaint supersedes the original).