(PC) Taylor v. Schultz
2:25-cv-00199
| E.D. Cal. | Jun 30, 2025Background
- Dionn Taylor, a state prisoner, filed a pro se civil rights complaint, seeking to proceed in forma pauperis.
- Taylor alleges that on November 15, 2024, Correctional Officer (C/O) Ellis staged an attack against him by providing false information to other inmates and then used excessive force (mace and twisting Taylor's arm).
- Other named defendants (Rodriguez, Warden Schultz, Sergeant Judd) were implicated by Taylor but not alleged to have directly participated in the excessive force.
- The court screened the complaint as required for prisoner filings to determine if it stated any viable claims.
- The court found a potential Eighth Amendment excessive force claim stated only against Ellis; all other claims/defendants were insufficiently pled.
- Plaintiff is given the option to proceed solely on the claim against Ellis or file an amended complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| In forma pauperis status | Taylor qualifies for in forma pauperis | N/A | Granted |
| Excessive force under 8th Amendment | Ellis used mace and twisted his arm | N/A | Sufficiently pled against Ellis for screening |
| Liability of other officers | Other officers were involved | N/A | Not sufficiently alleged; dismissed |
| Opportunity to amend | Wishes to maintain or expand claims | N/A | May amend complaint or proceed on Ellis claim only |
Key Cases Cited
- Hudson v. McMillian, 503 U.S. 1 (U.S. 1992) (discusses standards for excessive force claims under the Eighth Amendment)
- Monell v. Department of Social Services, 436 U.S. 658 (U.S. 1978) (requires a direct causal link between defendant’s actions and alleged constitutional violation)
- Rizzo v. Goode, 423 U.S. 362 (U.S. 1976) (supervisory liability requires personal involvement, not just supervisory status)
- Simmons v. Navajo County, 609 F.3d 1011 (9th Cir. 2010) (addresses requirement for personal participation in § 1983 claims)
- Ewing v. City of Stockton, 588 F.3d 1218 (9th Cir. 2009) (personal involvement required for liability under § 1983)
- Rodriguez v. County of Los Angeles, 891 F.3d 776 (9th Cir. 2018) (supervisory officials not liable solely due to position)