McIntyre v. Streight

Background

Bryson Jamal McIntyre, identified as a detainee at Santa Rita Jail, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. He alleged that he is a practicing Muslim and that Deputy Jonathan Streight took his prayer rug, told him he could not use it or identify himself as Muslim, pushed and assaulted him, and caused him to be removed from Ramadan meal service. McIntyre alleged that he was not provided food for four days.

Screening and Claims Allowed to Proceed

The court reviewed the complaint under 28 U.S.C. § 1915A, which requires screening of a prisoner’s complaint seeking relief from a governmental officer or entity. The court concluded that, when read generously, the complaint stated claims against Streight under the First Amendment’s Free Exercise Clause and the Religious Land Use and Institutionalized Persons Act for interference with McIntyre’s religious practice. It also found a claim under the Fourteenth Amendment based on the alleged assault and denial of food.

Claims and Defendants Dismissed

McIntyre also named the Alameda County Sheriff but made no allegations against that defendant. The court explained that § 1983 does not impose liability solely because a person supervises someone who allegedly violated another person’s rights. The court dismissed the claims against the Sheriff with leave to amend. More generally, the order dismissed the remaining claims and defendants with leave to amend. McIntyre could file an amended complaint identifying other responsible defendants and describing their actions, or could choose to proceed only against Streight.

Orders and Deadlines

The court ordered service of the complaint and the order on Streight without requiring advance payment of service fees. Streight was ordered to file a summary-judgment motion or another dispositive motion concerning the cognizable claims by October 9, 2025. If he raised failure to exhaust administrative remedies, the court directed him to do so through a summary-judgment motion. McIntyre’s opposition would be due 45 days after the motion, and Streight’s reply would be due 15 days after the opposition. The court also authorized discovery under the Federal Rules of Civil Procedure and provided instructions concerning communications, extensions, address changes, and responding to any summary-judgment motion.