Crosby v. Siordia

Background

Robert Lee Crosby, an inmate at California State Prison–Solano, filed this case without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims for violations of federal rights by people acting under state authority. The amended complaint named Salvador Siordia, a Correctional Training Facility correctional officer, and Koenig, identified as a former Correctional Training Facility warden.

The amended complaint alleged that Siordia searched Crosby’s cell on October 24, 2022, found inmate-made alcohol and an altered tablet, and issued two prison disciplinary charges. Crosby claimed that Siordia violated due process because prison regulations required a line supervisor to identify certain liquids and required the items to be logged. Crosby also alleged that Siordia violated California’s Bane Act through harassment and racist behavior and that Koenig acted negligently.

In the initial complaint, the court had found legally sufficient a First Amendment retaliation claim alleging that Siordia took Crosby’s shoes after Crosby threatened to file grievances. The amended complaint did not include that claim, the claims against officers Nunez and Martinez, or the Eighth Amendment claim concerning inmate safety.

Screening standard

Because Crosby is a prisoner seeking relief from a governmental officer, the court screened the amended complaint under 28 U.S.C. § 1915A. The court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a claim, or sought money from an immune defendant. The court also noted that pleadings filed without a lawyer must be read liberally, but they must still provide enough factual allegations to state a plausible claim.

Reasons for dismissal

The court held that the alleged violations of the prison’s internal procedures did not establish a federal due-process violation. Due process for prison disciplinary charges requires protections such as notice, an opportunity to prepare and present evidence, a written decision, and some reliable evidence supporting the disciplinary finding. It does not require prison officials to follow every procedure in their own regulations. The court therefore dismissed the due-process claim with prejudice because amendment would be futile.

The court found that the Bane Act allegations against Siordia were too vague and conclusory. They did not support a reasonable inference that Siordia threatened violence or caused harm through the alleged harassment and racist behavior.

The court also found that the amended complaint did not state a Section 1983 claim against Koenig. It did not allege a causal connection between Koenig and Siordia’s conduct. The court explained that a person is not liable under Section 1983 merely because that person supervised an alleged wrongdoer, and negligence is not actionable under Section 1983 in this prison setting.

The court further held that the amended complaint had replaced the original complaint and that Crosby’s failure to include the previously recognized retaliation claim meant that claim was currently waived. The amended complaint therefore left the case without an operative complaint or any cognizable claim.

Disposition

The court DISMISSED the amended complaint for failure to state a claim. It DISMISSED the due-process claim with prejudice and GRANTED Crosby leave to file a second amended complaint. The court ordered Crosby, by July 11, 2025, either to file a second amended complaint or to inform the court that he wished to proceed with the original complaint and the previously recognized First Amendment retaliation claim against Siordia. The court warned that failing to respond would result in dismissal of the action for failure to state a claim without further notice.