Goodwin v. Gomez

Background

Patrick Glen Goodwin, identified as a state prisoner, filed a civil-rights action under 42 U.S.C. § 1983 concerning events at Salinas Valley State Prison, where the opinion says he was incarcerated. The case was transferred from the Eastern District of California to the Northern District of California on September 23, 2024, and reassigned to Judge Beth Labson Freeman on January 30, 2025. The court said Goodwin’s request to proceed without paying the filing fee would be addressed separately.

Allegations

Goodwin alleged that, after returning from a medical appointment on November 27, 2023, Defendant A. Hidalgo ordered him into a cell that was not powered and was used for administrative segregation, even though he was not an administrative-segregation inmate. Goodwin alleged that he was seated in a mobility walker, experienced medical problems and rising blood pressure, temporarily lost consciousness, and was placed in excessively tight waist-chain restraints at Hidalgo’s request.

Goodwin further alleged that he told Hidalgo and other defendants that he felt unwell, light-headed, and might pass out. He alleged that, when defendants tried to lift him from his walker, Defendant L. Hernandez grabbed his shirt, Defendants M. Brito and A. Gomez pushed his face into the ground, and other defendants repeatedly hit various parts of his body. He alleged that he suffered abrasions and cuts. He also alleged that Defendants J. Rodriguez, G. Gonzalez, J. Perez, B. Rosiles, V. Mora, R. Ruiz, R. Reyes, A. Martinez, and R. Maciel failed to intervene. Finally, he alleged that Defendant Sembijwe, described as health-authority personnel, failed to accurately record all of his injuries and acted with deliberate indifference to his medical needs.

Screening analysis

The court conducted preliminary screening under 28 U.S.C. § 1915A. At this stage, the court must identify claims that are legally sufficient and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also stated that pleadings filed without a lawyer must be read liberally.

To state a claim under § 1983, a plaintiff must allege both a violation of a federal right and conduct by a person acting under state law. The court held that the allegations were sufficient to state excessive-force and failure-to-protect claims against the sixteen named correctional officers.

The court found the deliberate-indifference claim against Sembijwe insufficient. It explained that deliberate indifference to a prisoner’s serious medical needs violates the Eighth Amendment, but a plaintiff must show both a serious medical need and that the official knew of and disregarded a substantial risk of serious harm. The court concluded that allegations of abrasions and cuts did not establish a serious medical need. It also concluded that, even assuming Sembijwe’s injury report was deficient, Goodwin did not allege that Sembijwe knew that failing to record the injuries accurately created a substantial risk of serious harm and disregarded that risk.

Disposition

The court ordered that the action be dismissed with leave to amend. Goodwin was given 28 days from the filing of the order to submit an amended complaint on the court’s form, using the case caption and civil case number specified in the order and labeling it “FIRST AMENDED COMPLAINT.” The court stated that the amended complaint would replace the original complaint; claims omitted from it would no longer be claims, and defendants omitted from it would no longer be defendants.

The court further ordered that failure to file an amended complaint as directed would result in dismissal with prejudice of the deliberate-indifference claim against Sembijwe for failure to state a claim for relief. In that event, the matter would proceed on the excessive-force and failure-to-protect claims against the other defendants. The clerk was directed to provide two copies of the court’s form complaint with the order.