Jones v. Boulden

Background

Dyrell Wayne Jones, an incarcerated person proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 concerning events at Martinez Detention Facility. The court reviewed the complaint under the prisoner-screening statute, 28 U.S.C. § 1915A. That review requires the court to identify legally sufficient claims and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant.

Jones alleged that he is Muslim and that detention-facility personnel interfered with religious practices and items, including his kufi, prayer beads, religious diet, and religious grooming. He also alleged that medical staff discussed his medical conditions in an open area, and that food-service personnel gave him meals containing peanut butter or food prepared where peanut butter was packaged despite his allergy.

Claims Allowed to Proceed

The court held that the complaint stated a cognizable First Amendment free-exercise claim against Boulden, Lance, Cowan, and Cooper. The allegations included repeated demands that Jones remove his kufi, removal of his prayer beads, refusal to allow him to possess the beads accompanied by comments about Muslims, and refusal to provide head shavers that Jones said he needed for religious grooming.

The court ordered the Clerk to issue summonses and the United States Marshal to serve the operative complaint and the order on Boulden, Lance, Cowan, and Cooper without requiring Jones to pay service fees in advance.

Claims and Defendants Dismissed

The court dismissed the claims against Martinez Detention Facility Medical concerning privacy and dismissed the claims against Jose and Alma concerning meals containing peanut butter or sunflower butter. The court stated that these incidents were unrelated to the religious-practice claims for purposes of the federal joinder rule and that Jones would need to bring them in separate actions. Those dismissals were without prejudice to bringing the claims separately.

The court dismissed Jones’s Health Insurance Portability and Accountability Act claim with prejudice because it found no private right of action to enforce that statute or seek relief for its violation.

The court dismissed the religious-diet claim because the complaint said the diet was denied due to medical needs, and protecting inmate health is a legitimate correctional goal. The court granted leave to amend that claim if Jones could allege facts showing that the denial was not reasonably related to a legitimate correctional purpose.

The court dismissed Livingston and Layrana because the complaint made no allegations against them, but granted Jones leave to amend his claims against them. It dismissed Krosten, Rice, and Lee because the complaint did not state a legally sufficient civil-rights claim against them, but also granted leave to amend those claims. The court explained that a supervisor is not liable under § 1983 merely because of supervisory status, that handling a grievance generally does not establish personal liability for the underlying violation, that the alleged denial of out-of-cell time did not burden Jones’s religious practice, and that the allegation against Rice was unclear and did not state a claim.

Counsel and Further Procedure

The court denied Jones’s request for appointed counsel because he had adequately presented his claims, the likelihood of success was unclear at that stage, and the case did not present exceptional circumstances. The court stated that this denial was without prejudice to appointing counsel later if circumstances required it, such as if the case proceeded to trial.

Jones was given 28 days from the date of the order to file an amended complaint addressing the identified deficiencies. If he did not amend, the existing complaint would remain operative and the case would proceed only on the claim found cognizable against the defendants ordered served. The order also required the defendants to file a summary-judgment motion or another dispositive motion no later than 91 days after the order was filed, unless they informed the court that summary judgment could not resolve the case.