Lewis v. Segura

Background

Chauncey T. Lewis filed this self-represented action under 42 U.S.C. § 1983 against officials at Salinas Valley State Prison, where he had previously been housed. The court reviewed his first amended complaint under the required screening process for a prisoner seeking relief from government officials.

The original complaint named Sergeants G. Segura and D. Moreno and Officer J. Lopez. It alleged, in a single sentence, that officials falsified documents dated April 26, 2022, and sought money damages for pain, suffering, emotional stress, and negligence. The court previously dismissed that complaint with leave to amend because it did not identify a violation of federal law and did not explain what each defendant allegedly did.

The first amended complaint again listed Segura, Moreno, and Lopez in its caption, but it omitted Segura from the section identifying defendants and added Joel Marshall, a staff doctor at Natividad Medical Center. Lewis alleged that a camera in a medical examination room violated his rights, that a stent was placed in his upper left arm without his consent, and that he received disciplinary reports for aggravated battery, gassing Marshall, and destroying property. He also alleged that the reports were not provided or processed within time limits in prison or state regulations, that the resulting placement and transfer harmed him, and that the transfer was retaliatory.

Court’s Analysis and Rulings

The court held that the first amended complaint did not state a claim against Segura because it did not reference him. Segura was dismissed from the action with prejudice because Lewis had already been given an opportunity to correct the problem.

The court also held that the amended complaint did not state a claim against Marshall. The only allegation concerning Marshall was that Lewis received a disciplinary report for gassing him. Marshall was dismissed without prejudice to Lewis naming him in a second amended complaint if Lewis could truthfully state a claim.

The court dismissed the due-process claims against Moreno and Lopez with prejudice. It explained that the federal Due Process Clause requires certain basic protections in prison disciplinary proceedings, but does not by itself require prisons to follow every deadline in their own regulations. The alleged failure to provide a disciplinary report within 15 days or hold a hearing within 30 days therefore did not state a constitutional claim. The court also stated that due process does not create a right to avoid being placed in an examination room with a camera.

Because it remained unclear whether Lewis could state any legally recognizable § 1983 claims against the named defendants, the court granted him another opportunity to amend. It dismissed the first amended complaint with leave to amend and ordered Lewis to file a second amended complaint within 28 days. The new complaint must include all claims and defendants Lewis wishes to pursue and may not rely on material from the earlier complaints by reference. The court instructed him not to replead claims or rename defendants already dismissed with prejudice.

Evidence-Preservation Request

Lewis separately asked to begin discovery early to obtain and preserve camera and other audiovisual recordings from outside Natividad Medical Center. The court denied that request because there was no operative complaint and it was still unclear whether Lewis would state cognizable claims. The court said that discovery could begin if Lewis stated cognizable claims in a second amended complaint, and that Lewis would then need to serve discovery requests on the relevant entities.

Disposition

The court dismissed the first amended complaint with leave to amend, dismissed Segura with prejudice, dismissed Marshall without prejudice, dismissed the due-process claims against Moreno and Lopez with prejudice, and denied the motion for early discovery and evidence preservation. The order stated that failure to file a proper second amended complaint within the allowed period would result in dismissal of the action without further notice.