Maury v. Smith
- Jeffrey White
- 4:24-cv-07093
- U.S. District Court · Northern District of California
- 3
In Maury v. Smith, Judge White dismissed the inmate’s legal-mail civil-rights complaint with leave to amend because it did not identify responsible defendants or state a claim.
Robert E. Maury’s case was dismissed at the prisoner-screening stage, with permission to amend; the warden and unidentified mailroom staff were the defendants named in the dismissed complaint.
What happened
In Maury v. Smith, Robert E. Maury, an inmate proceeding without a lawyer, alleged that his legal mail was opened outside his presence, without notification, and not given to him. He sued the prison warden and unidentified mailroom staff under a federal civil-rights law.
The court found that Maury did not allege that the warden personally caused the mail problems, and a supervisor cannot be held responsible solely because of that supervisory role. The court also found that Maury could not sue a group called “mailroom staff” without identifying the individuals and describing what each person did or failed to do.
Judge Jeffrey S. White dismissed the complaint for failure to state a legally recognizable claim, but allowed Maury to file an amended complaint by November 28, 2024. The court said the case will be dismissed if he does not timely amend and correct the identified problems.
The detailed version
- Maury v. Smith · No. 4:24-cv-07093
- Jeffrey White
- Oct. 28, 2024
Background
Robert E. Maury, an inmate at Pelican Bay State Prison proceeding without a lawyer, filed a civil-rights case under 42 U.S.C. § 1983 against the warden and unidentified “mailroom staff.” He alleged that his legal mail was opened outside his presence, without notifying him, and was not provided to him.
Screening standard
Because Maury is a prisoner seeking relief from government officials or employees, the court screened the complaint under 28 U.S.C. § 1915A. Screening requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also explained that a § 1983 claim requires an alleged violation of a federal constitutional or statutory right by someone acting under state law.
Reasons for dismissal
The complaint named the warden but did not allege that the warden personally took, or failed to take, any action that caused the mishandling of Maury’s legal mail. The court stated that a supervisor is not liable under § 1983 simply because officials involved in an alleged violation worked under that supervisor.
The complaint also named “mailroom staff” as a group. The court held that Maury could not sue an unidentified group without naming the individuals and alleging the specific actions or omissions by each person that caused the alleged interference with, confiscation of, or other mishandling of his legal mail.
Disposition
The court dismissed the complaint for failure to state a cognizable claim for relief. It granted Maury leave to file an amended complaint on or before November 28, 2024. The amended complaint must use the caption and case number in the order and include the words “COURT-ORDERED FIRST AMENDED COMPLAINT” on its first page. It must replace the original complaint and include all claims Maury wishes to pursue; it may not incorporate the original complaint by reference. The court stated that failure to amend timely and cure the identified deficiencies will result in dismissal of the case. The order also directed Maury to comply with court orders and keep the court informed of any address change.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.