Casias v. Tapia-Alcazar

Background

Jacob Casias, a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against correctional officers and mental-health staff at Salinas Valley State Prison. He alleged that on April 24, 2023, Sgt. M. Meyer ordered officers to open his cell in the administrative-segregation unit. He further alleged that E. Barbosa, F. Tapia-Alcazar, Jr., M. Miranda, A. Morales, Y. Washington, D. Leon, and T. Tucker used excessive force while putting him in handcuffs, although he was not resisting. Casias alleged that he told the defendants he could not breathe and was going to hang himself, and that he suffered back and shoulder injuries and deep cuts to his hands and wrists from handcuffs that were too tight.

Casias also alleged that, between April 23 and June 29, 2023, he requested mental-health care while in administrative segregation because he was suicidal. He alleged that mental-health and correctional staff did not call a Crisis Intervention Team after he said he was going to hang himself. He later attempted to hang himself and was found unconscious by unnamed defendants, who provided emergency treatment. Casias sought declaratory relief and damages, including damages for emotional injuries.

Screening and Cognizable Claims

Because Casias is a prisoner seeking relief from government employees, the court screened the complaint under 28 U.S.C. § 1915A. The court explained that a § 1983 claim requires an alleged violation of a constitutional or federal-law right by someone acting under state authority. Construing Casias’s self-represented complaint liberally, the court found three types of cognizable claims: an excessive-force claim against the correctional officers who entered his cell; a claim that the unnamed mental-health staff were deliberately indifferent to his serious mental-health needs; and a claim for emotional injuries accompanied by physical injury that was more than minimal.

The court permitted Casias to use discovery to identify the unnamed defendants and to seek permission to amend the complaint to substitute their proper names. The opinion’s discussion of the Doe defendants is partly affected by an incomplete sentence in the provided text, but the court expressly gave Casias an opportunity to identify them through discovery.

Rulings and Case Schedule

Judge Beth Labson Freeman dismissed Correctional Officers Carcia, Arminata, and McNeil without prejudice because Casias made no specific factual allegations against them. The clerk was directed to terminate those defendants, and Casias was given 28 days from the filing of the order to seek leave to amend and attempt to state claims against them.

The court ordered service on Sgt. M. Meyer and Correctional Officers F. Tapia-Alcazar, Jr., T. Tucker, D. Leon, A. Morales, M. Miranda, and Y. Washington through the prison system’s electronic-service process. The court directed the defendants to file a summary-judgment motion or another dispositive motion addressing the cognizable claims within 91 days after the order was filed. It set deadlines for Casias’s opposition and the defendants’ reply and stated that no hearing would be held unless the court later ordered one.

The court also directed Casias to try to learn the names of the Doe defendants during discovery and to file a motion substituting their proper names within 56 days. The order states that failure to do so will result in dismissal of the claims against those defendants for failure to state a claim. Casias’s motion to proceed without paying the filing fee was left for decision in a separate order.