Woods
- Edward Davila
- 5:24-cv-06332
- U.S. District Court · Northern District of California
- 6
In Woods v. CDCR, Judge Davila screened the prisoner’s case, dismissed two defendants, and ordered service on the others while keeping the case stayed.
The plaintiff’s claims against CDCR and J. Clark Kelso were dismissed. The deliberate-indifference claim against the remaining individual defendants was found plausible, and those defendants were ordered served. The case remains stayed except for service.
What happened
In Woods v. CDCR, a California prisoner alleged that defendants violated his constitutional rights by transferring inmates, some infected with COVID-19, to San Quentin State Prison in May 2020. He brought the case without a lawyer and alleged deliberate indifference to his safety.
The court dismissed the California Department of Corrections and Rehabilitation because state agencies are protected from damages lawsuits in federal court. It also dismissed Prison Receiver J. Clark Kelso because he has immunity for the conduct at issue. The court found that the allegations stated a plausible Eighth Amendment safety claim against the other defendants in their individual capacities.
Judge Edward J. Davila ordered service on the remaining defendants, granted a motion to amend the lawsuit’s title, and kept the case stayed for all purposes other than serving the complaint.
The detailed version
- Woods · No. 5:24-cv-06332
- Edward Davila
- Feb. 13, 2025
Background
The plaintiff, a California prisoner proceeding without a lawyer, alleged that defendants violated his constitutional rights by transferring inmates from the California Institution for Men to San Quentin State Prison in May 2020, including inmates who were infected with COVID-19. He alleged that he contracted COVID-19 because of defendants’ deliberate indifference and unreasonable protocols.
The case was consolidated with related prisoner-transfer cases under the lead matter, In Re CIM-SQ Transfer Cases, No. 5:20-cv-06326-EJD. The individual case remained stayed except for service of the complaint. The court conducted screening under 28 U.S.C. § 1915A, which requires a court to review a prisoner’s complaint against governmental parties and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek damages from an immune defendant.
Claims and Defendants
The plaintiff named the California Department of Corrections and Rehabilitation (CDCR); Ralph Diaz; Ronald Davis; Ronald Broomfield; Lawrence Cryer; Allison Pachynski; Shannon Garrigan; Mona Houston; Kirk Torres; Louis Escobell; Muhammed Farooq; and J. Clark Kelso.
The court explained that a claim under 42 U.S.C. § 1983 requires allegations that a federal right was violated by a person acting under state law. Liberally construing the complaint, the court found a plausible claim that the remaining individual defendants were deliberately indifferent to the plaintiff’s safety, in violation of the Eighth Amendment.
Rulings
The court dismissed CDCR because it is a state agency and therefore is immune from § 1983 damages lawsuits under the Eleventh Amendment. The court also dismissed J. Clark Kelso based on quasi-judicial immunity.
The court ordered service on Ralph Diaz, Ronald Davis, Ronald Broomfield, Lawrence Cryer, Allison Pachynski, Shannon Garrigan, Mona Houston, Kirk Torres, Louis Escobell, and Muhammed Farooq. Service was ordered through CDCR’s electronic-service program for prisoner civil-rights cases, with further service by the U.S. Marshals Service for defendants who did not waive service.
The court granted the plaintiff’s motion to amend the title of the lawsuit. It also ordered that the case remain stayed for all purposes other than service. The opinion states that the plaintiff was to be granted permission to proceed without paying the filing fee by a separate order.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.