Nieto v. Allison
- Jon Tigar
- 4:24-cv-02628
- U.S. District Court · Northern District of California
- 2
In Nieto v. Allison, Judge Tiga denied Michael Nieto’s request to block alleged mail interference and camera-viewed strip searches.
Michael Nieto’s request for emergency injunctive relief was denied. The order also concluded that Valley State Prison officials, who were not parties to the action, could not be ordered by this court to change their conduct.
What happened
(PC) Nieto v. Allison involves Michael Nieto, an incarcerated person housed at Valley State Prison, who sued Correctional Training Facility officials under a federal civil-rights law. His underlying claims allege excessive force and refusal to decontaminate him after pepper spray was used.
Nieto asked the court to stop Valley State Prison officials from interfering with or reading his legal mail and from requiring strip searches in front of surveillance cameras when he traveled to certain activities. The court found that these allegations concerned different officials and different conduct from the claims in his complaint.
Judge Tiga denied Nieto’s request for a temporary restraining order or preliminary injunction. The court also explained that Valley State Prison officials were not parties to the case and were not shown to be acting together with the named defendants, so the court could not order them to act or refrain from acting.
The detailed version
- Nieto v. Allison · No. 4:24-cv-02628
- Jon Tigar
- Aug. 29, 2025
Background
Michael Nieto, who is currently housed at Valley State Prison, brought this self-represented action under 42 U.S.C. § 1983 against Correctional Training Facility correctional officials. The underlying complaint alleges that the officials used excessive force against him and refused to decontaminate him after pepper spray was used, violating the Eighth Amendment.
Nieto separately requested a temporary restraining order or preliminary injunction—an emergency court order requiring or prohibiting specified conduct. He asked the court to enjoin Valley State Prison officials from interfering with or reading his legal mail and from requiring him to undergo strip searches in front of surveillance cameras whenever he crossed work change for college, mental-health treatment, R&R, and education.
Reasons for the ruling
The court denied the request for two reasons.
First, the court held that the requested relief was not sufficiently connected to the claims in the underlying complaint. The complaint concerned alleged excessive force and deliberate indifference to serious medical needs by Correctional Training Facility officials. The request for injunctive relief instead alleged retaliation and interference with access to the courts by Valley State Prison officials. Because the requested relief involved different issues from those alleged in the operative complaint, the court found that it was not a proper basis for interim relief.
Second, Federal Rule of Civil Procedure 65(d) limits an injunction to the parties, their officers, agents, employees, attorneys, and people acting together with them. The named defendants were Correctional Training Facility officials, while the Valley State Prison officials were not parties. The court found no indication that the Valley State Prison officials were acting together with the defendants and concluded that it did not have jurisdiction over those officials for purposes of ordering them to act or refrain from acting.
Disposition
Judge Tiga denied Nieto’s request for a temporary restraining order or preliminary injunction. The order terminated ECF No. 21.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.