Hill v. Santiagos

Background

Cymeyon V. Hill, a civil detainee held at Napa State Hospital, filed a self-represented civil-rights complaint under 42 U.S.C. § 1983. The complaint named Medical Staff Santiagos, Tom, Monique, and Jennie Clay, and sought punitive and nominal damages. Hill alleged that on May 10, 2024, Santiagos used a racial slur, threatened punishment for filing lawsuits and grievances, and said that Monique and Clay had said Hill would suffer in Unit T8.

Screening and claims

The court explained that it was required to screen the complaint under 28 U.S.C. § 1915A. At this stage, the court must identify legally recognizable claims and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also stated that a claim under § 1983 requires an alleged violation of a federal constitutional or statutory right by a person acting under state law.

The court held that Hill stated a recognizable First Amendment retaliation claim against Santiagos, Monique, and Clay. A retaliation claim requires protected activity, an adverse action that could discourage an ordinarily firm person from continuing that activity, and a substantial causal connection between the protected activity and the adverse action.

The court dismissed, against Santiagos, Monique, and Clay, the claim based on verbal harassment and threats. It relied on decisions holding that verbal harassment, abuse, or a mere threat generally does not by itself state a claim under § 1983.

Mediation and case status

The court referred the action to Magistrate Judge Robert M. Illman for global settlement proceedings through the Pro Se Prisoner Mediation Program. The mediation may involve one or more conferences and Hill’s other cases. The conferences were to occur within 120 days of the order, or as soon afterward as the magistrate judge’s schedule allowed.

The Clerk was directed to send the defendants the lawsuit documents and service-waiver materials. After service of the complaint on the defendants against whom Hill stated recognizable claims, all further proceedings were stayed. If the case is not settled, the court will issue a scheduling order. The court also stated that Hill must serve future court communications on the defendants or their counsel, keep the court informed of any address change, and prosecute the case.

Disposition

The order recognized a First Amendment retaliation claim against Santiagos, Monique, and Clay; dismissed the verbal-harassment-and-threats claim against those three defendants; referred the action to mediation; and stayed further proceedings after service. The order does not state a separate disposition for defendant Tom.