Ramin Sariaslan v. Ronald Rackley
678 F. App'x 613
| 9th Cir. | 2017Background
- Plaintiff Ramin Sariaslan, proceeding pro se, sued under 42 U.S.C. § 1983 over food he purchased for Ramadan that he alleges was withheld or blocked by prison staff.
- The district court dismissed his complaint under 28 U.S.C. § 1915A and denied leave to amend.
- Sariaslan asserted claims including an alleged breach of contract and deprivation of property, plus allegations that officer Polasik interfered with his receipt of food he bought for a religious event.
- The district court found the breach-of-contract § 1983 claim deficient and held California law provides an adequate post-deprivation remedy for property claims, making them noncognizable under § 1983.
- The Ninth Circuit reviewed the dismissal de novo and considered whether dismissal without leave to amend was proper. The panel affirmed in part, vacated in part, and remanded for further consideration of the religious/free-exercise allegations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an alleged breach of contract can state a § 1983 claim | Sariaslan argued the prison staff breached an obligation regarding food he bought for Ramadan | Defendants argued contract-style claims do not state a constitutional § 1983 violation absent facts showing state action violating federal rights | Dismissed: breach-of-contract claim fails to state a § 1983 claim |
| Whether deprivation of property is cognizable under § 1983 | Sariaslan claimed his purchased food was taken/deprived | Defendants argued California provides adequate post-deprivation remedies, so § 1983 is not available | Dismissed: state-law post-deprivation remedy is adequate; § 1983 claim not cognizable |
| Whether interference with food for religious observance states a free-exercise / related claim | Sariaslan alleged Polasik hindered delivery of food for a religious event without good cause | Defendants treated allegations as property/contract issues and relied on dismissal grounds above | Vacated as to these allegations: court found possible free-exercise, RLUIPA, or equal protection theories that the district court overlooked and remanded for consideration |
| Whether dismissal was proper without leave to amend | Sariaslan sought leave to amend to cure defects | Defendants implicitly argued defects could not be cured | Affirmed re: contract/property claims (defects incurable); but district court must consider leave to amend regarding religious-claim allegations on remand |
Key Cases Cited
- West v. Atkins, 487 U.S. 42 (1988) (elements required to state a § 1983 claim)
- Barnett v. Centoni, 31 F.3d 813 (9th Cir. 1994) (California provides adequate post-deprivation remedies for unauthorized property deprivations)
- Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) (standard of review for dismissal under 28 U.S.C. § 1915A)
- Weilburg v. Shapiro, 488 F.3d 1202 (9th Cir. 2007) (leave to amend standard for pro se complaints)
- Jones v. Williams, 791 F.3d 1023 (9th Cir. 2015) (substantial-burden standard for free-exercise claims)
- Shakur v. Schriro, 514 F.3d 878 (9th Cir. 2008) (RLUIPA and equal protection frameworks for religious meal/diet claims)
- Lucas v. Dep’t of Corr., 66 F.3d 245 (9th Cir. 1995) (pro se litigant entitled to notice of deficiencies and opportunity to amend)