El-Shaddai v. Salinas Valley State Prison

Background

Adonai El-Shaddai, a state prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against Salinas Valley State Prison and other defendants. The court had allowed him to proceed without paying the filing fee. The court screened the complaint under the federal prisoner-screening statute, 28 U.S.C. § 1915A.

El-Shaddai alleged that he filed a prison staff complaint concerning the Americans with Disabilities Act on September 7, 2022, and a charge with the Equal Employment Opportunity Commission on August 10, 2023. He alleged that seven defendants then filed false Rules Violation Reports on February 8, August 18, and August 30, 2023, in retaliation for those filings. He stated that he lost 121 days of time credits because of the August 18 report and 30 days because of the August 30 report.

Court’s Analysis

The court explained that a prisoner claiming retaliation under the First Amendment must allege protected conduct, adverse action by a state actor because of that conduct, a chilling effect on the prisoner’s rights, and the absence of a legitimate correctional purpose for the action. The court found that El-Shaddai’s allegations were largely conclusory. He did not describe the substance of his Americans with Disabilities Act complaint or Equal Employment Opportunity Commission charge, say whether the defendants were involved in or knew about those filings, or provide enough detail about the defendants’ actions to show retaliation.

The court also discussed the rule commonly called the favorable-termination requirement. Under that rule, a Section 1983 claim seeking damages for conduct that would invalidate a conviction, sentence, or comparable prison decision generally cannot proceed unless the relevant conviction or decision has been reversed, expunged, declared invalid, or otherwise called into question through the specified procedures. The court stated that two of the Rules Violation Reports resulted in lost time credits affecting El-Shaddai’s release date. If he prevailed on claims challenging those reports, his release would be accelerated and the lawfulness of his continued confinement would be called into question. The court therefore required him to address why most of his claims were not barred by this rule.

Disposition

The court dismissed the complaint with leave to amend. El-Shaddai had 28 days from the filing date of the order to file an amended complaint. The amended complaint had to include all claims he wished to pursue, use the caption and civil case number in the order, and state “AMENDED COMPLAINT” on its first page. The court warned that failing to amend within the stated period would result in dismissal of the case. The order also directed him to keep the court informed of any address change and stated that failure to prosecute or comply with court orders could result in dismissal under Federal Rule of Civil Procedure 41(b).