Gaxiola v. Borla

Background

Joseph Emmanuel Gaxiola alleges that the California Department of Corrections and Rehabilitation (CDCR), Salinas Valley State Prison (SVSP), and Pleasant Valley State Prison (PVSP) discriminated against him because of disabilities arising from a gunshot wound and resulting traumatic brain injury that he suffered while incarcerated. He identifies grand mal seizures, migraines with nosebleeds and eye hemorrhages, photosensitivity, visual impairment with continuing vision loss, degenerative disc disease at multiple levels, and limited mobility.

Gaxiola alleges that the defendants failed to provide reasonable accommodations and excluded him from prison services and programs. The accommodations he describes include an accessible prison cell and bed without hard or sharp edges, a hat to protect against photosensitivity, and a clock and radio for visual impairment. He brings claims under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act in a complaint brought under 42 U.S.C. § 1983.

Screening and Claims

Because Gaxiola is a prisoner seeking relief from governmental entities, the court reviewed the second amended complaint under the federal prisoner-screening statute, 28 U.S.C. § 1915A. The court explained that screening requires dismissal of claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. It also noted that complaints filed without a lawyer must be read liberally.

The court concluded that Gaxiola stated claims for disability discrimination and failure to provide reasonable accommodations and medical treatment under the Americans with Disabilities Act and the Rehabilitation Act against CDCR, SVSP, and PVSP.

Order

The court ordered service of the second amended complaint and its attachments on CDCR, SVSP, and PVSP and directed those defendants to respond under Federal Rule of Civil Procedure 12. The order established an electronic-service process through CDCR, required CDCR to report which defendants would waive service, and directed the Clerk and the United States Marshals Service to serve defendants who did not waive service.

The court also reminded Gaxiola that requests for access to nonconfidential medical, central, and other relevant records must be made directly to prison or jail officials rather than to the court. It dissolved the stay entered earlier in the case and set a case-management conference for January 7, 2025, with a joint statement due January 3, 2025.