Scott v. CDCR

Background

James Scott, an incarcerated person housed at Salinas Valley State Prison, filed a self-represented action under 42 U.S.C. § 1983. The complaint named the California Department of Corrections and Rehabilitation (CDCR) and correctional officers A. Ventura, C. Camacho, R. Martinez, and R. Jimenez.

Scott alleged that on July 3, 2025, while he was handcuffed behind his back and not resisting, Ventura, Camacho, Martinez, and Jimenez slammed his face into the side of a sharp metal cage. He alleged that the incident knocked out his front tooth and split open his left eyelid, causing severe damage and disfigurement. He also alleged that, after he told the officers that he had post-traumatic stress disorder, mental trauma, depression, and humiliation related to a history of sexual assault, Camacho began ripping off his clothes. Scott claimed that these actions violated the Fourth and Eighth Amendments and sought $750,000 in compensatory damages.

Screening analysis

Because Scott is incarcerated and sued governmental defendants, the court screened the complaint under 28 U.S.C. § 1915A. At this stage, the court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, inadequately pleaded, or sought money from an immune defendant. The court also stated that self-represented pleadings must be read liberally.

The court explained that a § 1983 claim requires allegations that a federal constitutional or statutory right was violated and that the violation was committed by a person acting under state authority.

The court found two cognizable Eighth Amendment claims against Ventura, Camacho, Martinez, and Jimenez. First, it held that the allegation that the officers slammed Scott’s face into the metal cage while he was handcuffed and not resisting stated an Eighth Amendment excessive-force claim. Second, it held that the allegation that Camacho ripped off Scott’s clothes after Scott disclosed his history of sexual assault stated an Eighth Amendment sexual-harassment claim.

The court dismissed the Fourth Amendment claims with prejudice because the complaint did not allege a search or seizure and the court found that amendment would be futile.

The court also dismissed CDCR from the action with prejudice. It gave two reasons: the Eleventh Amendment generally barred the claims against CDCR, a state agency, and Scott had not directly linked CDCR to the alleged use of force or sexual harassment. The court explained that § 1983 does not impose liability merely because an entity supervised an alleged wrongdoer.

Disposition and next steps

The court ordered that the four prison officers be served through CDCR’s electronic service program for prisoner civil-rights cases. It ordered defendants to file and serve a summary-judgment motion or another dispositive motion no later than 91 days after the order was filed, unless they informed the court that summary judgment could not resolve the case. The order set deadlines for Scott’s opposition and defendants’ reply and stated that no hearing would be held on the motion.

The court also stated that discovery could proceed under the Federal Rules of Civil Procedure. It advised Scott about the requirements for opposing a future summary-judgment motion and directed him to send copies of his court filings to defendants or their counsel. The Eighth Amendment claims against A. Ventura, C. Camacho, R. Martinez, and R. Jimenez therefore proceeded, while the Fourth Amendment claims and CDCR were dismissed with prejudice.