(PC) Payton v. Sacramento County
2:25-cv-00234
E.D. Cal.May 22, 2025Background
- Plaintiff Mtula Tashamby Payton, an inmate, brought a pro se § 1983 claim against Sacramento County based on alleged failure to protect him from gang violence in jail.
- Plaintiff claims correctional officers transferred him, a Crips member, to a unit housing rival gang members, leading to an attack during a family visit.
- He alleges officers were deliberately indifferent and that one officer used excessive force post-attack, and a sergeant encouraged violence against inmates.
- Only Sacramento County is named as a defendant; no specific allegations are made against the county entity itself.
- The court screened the complaint under 28 U.S.C. § 1915(e), finding it fails to meet federal pleading standards and does not state a viable claim against Sacramento County.
- Plaintiff’s request to proceed in forma pauperis was granted; the complaint was dismissed with leave to amend within 30 days.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to protect from harm | Jail knowingly exposed him to violence from rivals | No direct allegations | Complaint fails to state a claim against named defendant |
| Excessive force | Officer used force after plaintiff was attacked | No direct allegations | No viable excessive force claim against named defendant |
| Entity liability (Rule 8) | County is responsible for officers’ actions | No specific county action | Complaint lacks specific allegations against county |
| Right to amend | — | — | Plaintiff given leave to amend within 30 days |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (sets plausibility standard for pleadings)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions are insufficient to state a claim)
- Haines v. Kerner, 404 U.S. 519 (1972) (pro se complaints must be liberally construed)
- Kobold v. Good Samaritan Reg’l Med. Ctr., 832 F.3d 1024 (9th Cir. 2016) (exact legal theory need not be pled)
- Bruns v. Nat’l Credit Union Admin., 122 F.3d 1251 (9th Cir. 1997) (liberal construction cannot supply essential factual elements)
- Lacey v. Maricopa Cnty., 693 F.3d 896 (9th Cir. 2012) (amended complaint supersedes prior complaint)