Woods v. Grant

Background

Michael Earl Woods, a state prisoner at San Quentin Rehabilitation Center, filed a civil-rights action without a lawyer concerning medical care at that facility and San Joaquin General Hospital. The court had previously dismissed the action for failure to comply with General Order No. 76 and entered a judgment. After Woods sent a letter explaining why he wanted to file his complaint by mail, the court allowed filing by mail, vacated the prior judgment, and reopened the case.

Screening standard

Because Woods sought relief from governmental entities or personnel while incarcerated, the court screened the complaint under 28 U.S.C. § 1915A. That statute requires the court to identify legally sufficient claims and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also explained that allegations filed without a lawyer are read generously, but still must provide enough facts to give defendants fair notice of the claims.

To state a claim under 42 U.S.C. § 1983, a plaintiff must allege both a violation of a federal constitutional or statutory right and action by a person acting under state authority.

Allegations and analysis

Woods alleged that Dr. Matolo performed surgery on the wrong hernia at San Joaquin General Hospital. Woods said that he discussed the surgery with Dr. Grant in November 2022 and told Grant that Matolo had operated on the left side, where there had been an old hernia repair, instead of the right side, which remained painful. Woods alleged that Grant referred him for further surgical evaluation. He also named T. Woodson, who provided an institutional-level response to Woods's grievance about the surgery. Woods alleged that Matolo was negligent and violated California law.

The court concluded that Woods had not stated a constitutional claim against any named defendant. As to Grant, the court said Woods had not explained how Grant was responsible for the alleged surgical error or how Grant failed to provide adequate treatment. The court found that referring Woods for further surgical evaluation was not an inadequate response to the complaint. The court also stated that a prison official is not liable under § 1983 merely for reviewing and responding to a grievance, so Woods had not stated a legally sufficient claim against Woodson. The order stated that Woods could amend to explain whether any defendant violated his constitutional rights.

Disposition

The court ordered the clerk to vacate the prior judgment and reopen the case. It granted Woods leave to file his complaint and application to proceed without paying filing fees by mail, with the application to proceed without paying filing fees also addressed by a separate order. The court dismissed the complaint with leave to amend because the allegations did not establish a federal claim against any named defendant.

Woods was given 28 days from the date of the order to file a First Amended Complaint. The order required that filing to include all allegations he wished to pursue and stated that the amended complaint would replace the original complaint. It warned that failure to amend within the specified time would result in dismissal of the case with prejudice. The order also stated that Woods must prosecute the case, keep the court informed of any address change, and comply with court orders, or the action could be dismissed for failure to prosecute.