Matthews v. Foss

Background

Ivan Lee Matthews, a California prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 against T. Foss and M. Atchley, identified as current and former wardens of Salinas Valley State Prison. A magistrate judge previously found that the complaint stated a legally cognizable Eighth Amendment claim, and the case was later reassigned to Judge Beth Labson Freeman.

Matthews alleged that he was placed on suicide watch in administrative segregation for 22 days after drugs were found in his cell, even though he was not suicidal. He alleged that cell checks occurred every 10 to 20 minutes and that loud noise continued around the clock, causing extreme sleep deprivation, high blood pressure, and pain. He alleged that he later sent inmate requests to Foss and Atchley about the conditions and their alleged failure to train and supervise correctional officers.

Motion for judgment on the pleadings

Foss and Atchley moved under Federal Rule of Civil Procedure 12(c) for judgment on the pleadings. This procedure allows a court to decide whether, accepting the complaint’s factual allegations as true, the defendants are entitled to judgment as a matter of law. They argued that Matthews had not alleged enough facts to make them liable for the actions of subordinate officers.

Matthews relied on supervisory liability. Under the law discussed by the court, a supervisor may be liable under § 1983 for personal involvement, a sufficient causal connection, culpable action or inaction in training or supervision, acquiescence in a constitutional violation, or reckless or callous indifference to constitutional rights. The court concluded that Matthews’s allegations were too general. The complaint did not allege that Foss or Atchley knew about the placement and conditions when they occurred, that either warden trained or normally supervised the particular officers, or that the officers acted because of inadequate training or supervision. The court also concluded that Atchley could not be liable for failing to train officers before he became a warden.

Qualified immunity

The defendants also asserted qualified immunity, a legal protection that generally shields government officials from damages liability unless their conduct violated a clearly established statutory or constitutional right. They relied on a Ninth Circuit decision involving sleep deprivation caused by noise during court-ordered suicide-watch checks.

The court agreed that qualified immunity applied. It concluded that, in 2019, clearly established law did not put a reasonable prison official on notice that conducting suicide-watch checks involving frequent cell checks and resulting noise violated the Eighth Amendment. The court therefore granted the motion for judgment on the pleadings based on qualified immunity as well.

Physical-injury argument and disposition

The defendants separately argued that the Prison Litigation Reform Act barred Matthews from recovering damages for mental or emotional injuries because he had not shown a qualifying physical injury. The court explained that this restriction applies to claims for mental or emotional injury, not all prisoner civil-rights claims. It does not bar claims for declaratory or injunctive relief, compensatory damages based on other injuries, or nominal or punitive damages not based on a specified injury.

Because Matthews alleged pain and high blood pressure and sought declaratory and punitive damages, the court held that the defendants were not entitled to judgment on the pleadings on the physical-injury ground.

The court granted in part and denied in part the defendants’ motion. It granted judgment on the pleadings concerning the Eighth Amendment claim based on supervisory liability and qualified immunity, and dismissed that claim against T. Foss and M. Atchley with prejudice. It denied the motion to dismiss based on failure to allege physical injury. The court stated that amendment would not be allowed because any amendment would be futile.