White v. Dr. Adeyamo

Background

Jessie Taylor White, a prisoner housed at Salinas Valley State Prison, filed an action without a lawyer under 42 U.S.C. § 1983. That statute allows a person to seek relief for a violation of a federal constitutional or statutory right by someone acting under state authority. The court reviewed the complaint under the prisoner-screening requirement in 28 U.S.C. § 1915A. White had separately been allowed to proceed without prepaying the filing fee.

The complaint named “Warden, my CC2 treatment team, & 2 med drs.” White said he could not obtain the individuals’ full names because they refused to provide them. He alleged that his religious beliefs prohibit consuming man-made medication, that officials falsely characterized those beliefs as part of his mania and obtained a court order allowing medication to be administered forcibly, and that he was being medicated against his will. He also alleged that the medications had side effects that endangered his life and health.

Reasons for Dismissal

The court identified three principal deficiencies.

First, the complaint used unnamed defendants. The court stated that unnamed defendants generally must be identified so they can be served. In an amended complaint, White must identify by name the prison official or medical personnel who allegedly violated his rights, using available medical records or a prison form if necessary.

Second, the complaint did not identify the federal constitutional provision or federal law allegedly violated. The court said White might be attempting to assert a First Amendment religious-freedom claim and an Eighth Amendment claim based on deliberate indifference to serious medical needs, but the allegations did not state either claim.

For a First Amendment religious-freedom claim, the court explained that White needed to identify the religion and the religious belief or practice prohibiting man-made medication. The court found that his general assertion that officials violated his religion was not enough. For an Eighth Amendment medical-care claim, White needed to provide facts showing both a serious medical need and a deliberately indifferent response. The court found that the general statement that the medications endangered his life and health was insufficient.

Third, the complaint did not connect the warden, the CC2 team, or the two unnamed doctors to specific actions or failures to act. Referring generally to “everyone” or “defendants” did not establish the required causal connection between a particular defendant and an alleged violation.

Disposition

The court dismissed the complaint for failure to state a claim but granted White leave to amend. Within 28 days of the order, he was required to file an amended complaint using the case caption and civil case number specified in the order and marking the first page “AMENDED COMPLAINT.” The amended complaint had to include all claims and defendants White wished to pursue and could not incorporate the prior complaint by reference. The court stated that failure to file a compliant amended complaint within the allotted time would result in dismissal of the action without further notice. The order was signed by United States District Judge Haywood S. Gilliam, Jr.