Smith v. Alameda County Sheriff Dept
- Martinez-Olguin
- 3:22-cv-07200
- U.S. District Court · Northern District of California
- 8
In Smith v. Officer Susaki, Judge Martinez-Olguin dismissed Smith’s amended civil-rights complaint with leave to amend because its claims and defendants were improperly joined.
D’Andre Smith, the self-represented prisoner plaintiff, must file a properly joined second amended complaint within 28 days to continue pursuing claims against the remaining defendants. The claims against the Alameda County Sheriff’s Department and Valley Care Hospital were dismissed because those entities were not named in the amended complaint.
What happened
In D’Andre Smith v. Officer Susaki, et al., D’Andre Smith, representing himself, sued under a federal civil-rights law over alleged mistreatment at Santa Rita Jail. He sought money damages and named Officers Middlebrook and Susaki.
The court found that Smith’s amended complaint again combined unrelated claims involving different defendants. The allegations concerned dental treatment, a strip search, underwear allegedly placed in his socks, and an incident involving medical workers and an X-ray. The court also noted that Smith had not included the Alameda County Sheriff’s Department or Valley Care Hospital as defendants in the amended complaint.
The court dismissed the amended complaint with leave to amend and gave Smith 28 days to file a second amended complaint that clearly identifies each claim, defendant, alleged conduct, injury, exhaustion of administrative remedies, and properly joined claims. Judge Araceli Martinez-Olguin also dismissed the claims against the two entities omitted from the amended complaint.
The detailed version
- Smith v. Alameda County Sheriff Dept · No. 3:22-cv-07200
- Martinez-Olguin
- July 15, 2024
Background
D’Andre Smith, who was incarcerated at Calipatria State Prison and represented himself, brought a civil-rights action under 42 U.S.C. § 1983 based on alleged constitutional violations at Santa Rita Jail, where he had previously been incarcerated. He sought monetary damages. The court had previously screened his original complaint under the prisoner-screening statute, 28 U.S.C. § 1915A, and dismissed it with leave to amend. Smith then filed an amended complaint naming Officers Middlebrook and Susaki.
Court’s analysis
The court screened the amended complaint under § 1915A. It explained that a § 1983 claim requires allegations showing both a violation of a federal constitutional or statutory right and action by a person acting under state law. The complaint also had to satisfy Federal Rule of Civil Procedure 8, which requires a short, plain, simple, concise, and direct statement giving defendants fair notice of the claims.
The court concluded that Smith’s amended complaint repeated the joinder problems identified in the earlier order. The amended complaint asserted four apparently unrelated claims against different defendants:
- In 2021, unknown dental staff allegedly chipped Smith’s teeth during dental treatment.
- After an attorney visit on an unknown date, Officer Susaki allegedly strip-searched Smith in front of other people.
- Between November and December 2021, while Officer Middlebrook was on laundry-exchange duty, Smith allegedly found a pair of panties inside his socks.
- Between April and June 2022, unknown medical personnel from Valley Care Hospital allegedly flipped Smith while taking stomach X-rays and pushed handcuffs into his mouth, causing his teeth to chip.
Under Rule 20(a), defendants may be joined only when the claims against them arise from the same transaction, occurrence, or series of transactions or occurrences and involve a common question of law or fact. The court found that Smith had not clearly shown that these claims satisfied those requirements. It also instructed that Smith must identify the specific acts or omissions of each defendant, the injury resulting from each claim, how each defendant was directly linked to the alleged violation, and whether the relevant hospital workers were government actors or private parties. The court further instructed Smith to explain how he exhausted his administrative remedies for each claim against each defendant.
Disposition
The court DISMISSED the claims against the Alameda County Sheriff’s Department and Valley Care Hospital because Smith did not include those entities as named defendants in the amended complaint. The court also DISMISSED Smith’s amended complaint with leave to amend, giving him one further opportunity to file a second amended complaint containing only properly joined claims and defendants. The second amended complaint had to be filed within 28 days, use the court’s civil-rights form, and completely replace the earlier complaints.
Judge Araceli Martinez-Olguin ordered the Clerk to send Smith a blank civil-rights complaint form. The order did not decide whether Smith’s underlying constitutional allegations were true or whether they ultimately stated viable claims.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.