Saifullah v. Macomber

Background

Khalifah E.D. Saifullah, a state prisoner at San Quentin Rehabilitation Center, filed a complaint without a lawyer under 42 U.S.C. § 1983, a federal civil-rights law. He alleged that, during a search of multiple cells on February 9, 2024, he was ordered to leave his cell wearing only his boxers and a T-shirt. He said he was then held in an outdoor exercise cage for three hours, from 4:30 p.m. to 7:30 p.m., in cold weather without proper clothing. He alleged that he trembled, became sick, and was deprived of a basic necessity of life.

Saifullah sued Jeff Macomber, identified as the California Department of Corrections and Rehabilitation Secretary, and Chance Andes, identified as the San Quentin Rehabilitation Center warden. He alleged that they approved or authorized the search. His claims asserted an Eighth Amendment violation under Section 1983 and a claim under California’s Bane Act, based on the court’s supplemental jurisdiction over the state-law claim.

Earlier Screening Order and Amended Complaint

The court screened the original complaint under 28 U.S.C. § 1915A, which requires federal courts to review certain prisoner complaints. The court dismissed the complaint but allowed Saifullah to amend it. It explained that an Eighth Amendment prison-conditions claim requires facts showing both a sufficiently serious deprivation and deliberate indifference—that is, that officials knew about and disregarded an excessive risk to health or safety.

The earlier order stated that recorded temperatures at the facility during the relevant three-hour period ranged from 56 to 51 degrees Fahrenheit. It said that wearing shorts and a T-shirt for three hours in those conditions might be unpleasant but did not by itself appear sufficiently serious to support an Eighth Amendment violation. The court also said Saifullah needed to allege specific facts showing that Macomber and Andes knew the search would be conducted in a way presenting an excessive risk and disregarded that risk.

Saifullah timely filed a First Amended Complaint. It repeated the central allegations, asserted that the temperature was as low as 45.9 degrees Fahrenheit, stated that he was 69 years old at the time, and alleged that he suffered a stroke on November 30, 2024, several months after the search.

Ruling

The court dismissed the First Amended Complaint under 28 U.S.C. § 1915A(b) for failure to state a claim under Section 1983. It concluded that Saifullah still had not alleged facts showing that the three-hour placement in the outdoor holding cage caused a substantial deprivation of a basic necessity of life. The court also concluded that the alleged stroke nearly ten months later was not a reasonably foreseeable consequence of the three-hour placement in approximately 50-degree weather.

The court separately found that Saifullah had not alleged specific facts showing that Macomber and Andes knew the search would pose an excessive risk to his health or safety and failed to take reasonable steps to reduce that risk. At most, the court said, the allegations suggested that the defendants should have known the search could place an older prisoner at serious risk of injury. The court held that this amounted to negligence or gross negligence, which is not actionable under Section 1983 in this prison context.

The court ordered that no further amendment be allowed. It dismissed any potentially viable California Bane Act claim without prejudice to bringing that claim in California courts. The clerk was directed to close the case and terminate all pending motions as moot.