Stelly v. Martinez Detention Facility

Background

Kamani Courvoisier Stelly, an inmate at the Martinez Detention Facility of the Contra Costa County Jail, filed this civil-rights action without an attorney under 42 U.S.C. § 1983. The court granted permission to proceed without paying the filing fee in a separate order.

Stelly alleged that he fell from his top bunk, his back “locked up,” and he could not move. His cellmate called for medical care while Stelly lay on the floor in “excruciating pain.” Stelly said he yelled that he was in pain and could not feel his legs. An officer and a nurse allegedly said they would call for medical assistance but did not do so. About an hour and a half after the fall, Stelly tried to stand, fell again, and struck his head. An officer then saw that he was bleeding and called for medical attention.

Screening Standard

Because Stelly sought relief from a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. Screening requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also stated that pleadings filed without an attorney must be read liberally, but a complaint still must provide enough facts to make a claim plausible rather than merely offering labels or conclusions.

To state a claim under § 1983, a plaintiff must allege both a violation of a constitutional or federal right and conduct by a person acting under state law.

Defendant and County Liability

The complaint named “Martinez Detention Facility Medical/Custody” as the defendant. The court held that this was not a proper defendant because the facility is operated by Contra Costa County and is not an independent legal entity capable of being sued.

The court explained that Stelly may sue Contra Costa County under § 1983 if a county policy or custom caused the constitutional violation. A county cannot be held liable merely because it employs officials who allegedly violated a person’s rights. Instead, Stelly would need to allege facts showing a constitutional right, a county policy, deliberate indifference to that right, and that the policy was the moving force behind the violation.

The court found that Stelly had not alleged that the County had a custom or policy at the jail that caused him to receive medical care late. The allegations that an officer and nurse failed to summon care, followed by an officer later summoning care, were not enough by themselves to plausibly identify a county policy or custom.

Disposition

The court dismissed the complaint with leave to amend. Stelly may amend to name Contra Costa County and may also name individual jail employees whose actions caused a constitutional violation. The amended complaint must include all claims Stelly wishes to pursue because it will replace the original complaint rather than supplement it.

The order states that the amended complaint was due by August 20, 2024, and warns that failure to file a timely or sufficient amendment may result in dismissal. It also states that Stelly must keep the court informed of any address change and comply with court orders. The order was dated July 18, 2025.