(PC) Yartz v. Coalinga State Hospital
1:15-cv-00006
E.D. Cal.Nov 14, 2016Background
- Plaintiff Norman E. Yartz, a civil detainee at Coalinga State Hospital under the Sexually Violent Predator Act, sued under 42 U.S.C. § 1983 alleging staff used force and mental abuse.
- Defendants named: Coalinga State Hospital and psych techs Luke Knoll, James Petterson, and R. Casper.
- Allegations: Knoll searched Plaintiff’s room and tried to take a remote from him; Plaintiff attempted to strike Knoll; Petterson placed Plaintiff in a choke hold; an unidentified psych tech allegedly engaged in "mental abuse" and discussed Plaintiff’s federal case; Plaintiff threatened the staff member.
- Procedural history: Original complaint dismissed with leave to amend; Plaintiff filed a First Amended Complaint; case screened under 28 U.S.C. § 1915(e)(2)(B).
- Court found the amended pleading failed to state any cognizable § 1983 claims, identifying lack of injury or objective-unreasonableness, absence of municipal policy or deliberate indifference, no linkage to R. Casper, and vague mental-abuse allegations.
- Court dismissed the action with prejudice and directed the Clerk to close the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Excessive force (Fourteenth/Fourth Amendment) | Knoll and Petterson used force (remote struggle; choke hold) amounting to punishment/assault | Use of force was incident to a search; Plaintiff resisted and no excessive or brutal force shown | Dismissed — allegations insufficient; no injury shown and force not objectively unreasonable |
| Municipal liability (Coalinga State Hospital) | Hospital liable for staff conduct | Hospital argues no policy/custom or deliberate indifference pleaded | Dismissed — no facts linking hospital policy/omission to constitutional violation |
| Failure to link defendant (R. Casper) | Casper named as defendant | No specific conduct alleged by Casper | Dismissed — no causal/linking allegations against Casper |
| Mental abuse / state tort claims | Psych techs verbally abused Plaintiff and discussed his case; Plaintiff threatened staff | Verbal harassment and state torts do not state § 1983 claims absent constitutional violation | Dismissed — allegations too vague to state a federal claim; state tort claims not actionable under § 1983 |
Key Cases Cited
- Swierkiewicz v. Sorema N. A., 534 U.S. 506 (2002) (plain statement/notice pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (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) (municipal liability requires policy/custom or deliberate indifference)
- Graham v. Connor, 490 U.S. 386 (1989) (objective reasonableness test for use of force)
- Smith v. City of Fontana, 818 F.2d 1411 (9th Cir. 1987) (excessive force that shocks conscience violates substantive due process)
- Gibson v. County of Washoe, 290 F.3d 1175 (9th Cir. 2002) (civil detainees entitled to more considerate treatment; use-of-force analysis)