Saddozai v. Atchley

Background

Shikeb Saddozai, a state inmate proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against S. Tomlinson at Salinas Valley State Prison. The complaint alleges a First Amendment violation. Settlement proceedings did not succeed, and on February 26, 2025, the case was referred to the Federal Pro Se Program to try to find trial counsel for Saddozai.

Saddozai then filed a motion for a temporary restraining order and preliminary injunction seeking to ensure his access to the courts at San Quentin Rehabilitation Center, where he was housed. He also filed an emergency application seeking to prevent an allegedly unauthorized transfer to another facility.

Rulings

The court denied the motion for a temporary restraining order and preliminary injunction. It explained that an injunction generally binds the parties to the action and certain people acting with them. The people named in Saddozai’s request were not parties to this action. Because the court lacked authority to enforce an injunction against those nonparties, it concluded that it should not issue the requested order.

The court also denied the emergency application to prevent the transfer. Saddozai relied on Federal Rule of Appellate Procedure 23(a), but the court explained that the rule applies to prisoners in habeas proceedings seeking release, not to this civil-rights action. The court further stated that prisoners generally have no constitutional right to incarceration in a particular institution and may generally be transferred without violating the Constitution.

Judge Beth Labson Freeman’s order terminated Docket Nos. 100, 101, and 102. The order addressed the requested emergency and injunctive relief; it did not decide the underlying First Amendment claim.