Goodlow v. Broomfield

Background

Sherode Goodlow, a state prisoner at San Quentin Rehabilitation Center, filed this civil-rights lawsuit without a lawyer under 42 U.S.C. § 1983. He named Warden Broomfield and Correctional Officers Malikan, Forter, Gonzalez, Smith, Santos, Chohan, and McCaffrey. The complaint alleged that prison employees retaliated against him for filing inmate grievances and denied him restroom access despite his claimed bladder problems. Goodlow sought monetary and punitive damages.

Screening standard

Because Goodlow was a prisoner suing government employees, the court conducted the required initial screening under 28 U.S.C. § 1915A. At this stage, the court identifies claims that are legally sufficient and dismisses claims that are frivolous, fail to state a claim, or seek relief from an immune defendant. The court also applied the rule requiring a complaint to give each defendant fair notice of the specific conduct allegedly violating the plaintiff’s rights.

First Amendment retaliation claim

The court found that Goodlow stated a cognizable First Amendment retaliation claim against Defendant Smith. Goodlow alleged that Smith berated him about his grievances, denied him access to the canteen, and tried to prevent him from using the law library. The court concluded that, liberally construed, these allegations sufficiently connected Smith’s actions to Goodlow’s protected activity of filing grievances.

The court found the retaliation allegations against the other defendants insufficient because Goodlow had not shown a substantial causal connection between his grievances and those defendants’ actions. The court therefore dismissed the retaliation claim against the defendants listed in the order—Broomfield, Malikan, Forter, Gonzalez, Santos, Chohan, Vong, and Pelte—with leave to amend. The opinion’s earlier discussion instead identifies McCaffrey among the defendants whose retaliation allegations lacked sufficient causation, creating an inconsistency in the defendant lists.

The court also dismissed any claim based on verbal harassment or threats, explaining that allegations of verbal abuse or a bare threat, without more, do not state a claim under Section 1983.

Eighth Amendment claim

Goodlow alleged that employees refused to let him use a restroom on July 6 and July 28, 2022, even after he told them about his bladder problems. The court held that the allegations did not presently show an objectively serious deprivation or the deliberate indifference required for an Eighth Amendment conditions-of-confinement claim. The court also found that Goodlow did not adequately link Smith to the alleged Eighth Amendment violation.

The court dismissed the Eighth Amendment claim with leave to amend against Broomfield, Malikan, Forter, Gonzalez, Santos, Smith, Chohan, Vong, and Pelte. It instructed Goodlow to provide more facts about the defendants’ state of mind and the harm he suffered, including why the temporary denial of restroom access was sufficiently serious.

Order and next steps

The court gave Goodlow 28 days to file an amended complaint. Any amended complaint had to include all claims he wished to pursue, including the dismissed claims and the retaliation claim against Smith, and could not incorporate the earlier complaint by reference. If he did not amend as ordered, the court stated that the dismissed claims would be dismissed, the initial complaint would remain operative, and the case would proceed under the order.

The court directed the Clerk to serve Smith and set procedures for the defendants’ answer, later dispositive motions, discovery, and communications with the court. The court’s order was signed by Chief Magistrate Judge Donna M. Ryu.