Hayes v. Doe

Background

Kevin Lewis Hayes filed a lawsuit concerning incidents at Correctional Training Facility in Soledad, California. The court had granted his motion to amend the complaint and reviewed the operative complaint under 28 U.S.C. § 1915A, which requires preliminary screening of prisoners’ claims against governmental entities and their officers or employees.

Hayes alleged that he had experienced problems sending legal mail to attorneys since 2021. He described a letter to Benjamin Pavonca that was returned opened with a note stating that the address did not exist. He also alleged that, on May 16, 2024, he sent legal mail intended for attorney Caneel Ciara Fraser to the Los Angeles County Courthouse. Correctional officers sealed the letter as legal mail, but it was later opened outside Hayes’s presence and returned to him about six weeks later. The letter included a note stating that Fraser did not exist and that her address was frivolous. Officers Robles and Partida placed the opened letter under Hayes’s door and refused Hayes’s request that they sign a statement about who opened it.

Hayes alleged that he believed Fraser would have received the letter if it had been mailed as addressed. A grievance response stated that the letter was addressed to “Camille Frazier” and that the mailroom determined no person with that name was admitted to the California State Bar. Hayes identified Lopez, Binning, and Garcia as the people whose names the prison provided when he sought information about mailroom staff responsible for mail on the relevant date. He sought monetary and injunctive relief.

Legal standard

The screening statute requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also explained that a complaint must include enough factual allegations to make a claim plausible, rather than relying only on labels or legal conclusions. Because Hayes was proceeding without a lawyer, the court said his pleadings must be read liberally.

To state a claim under 42 U.S.C. § 1983, a plaintiff must allege both a violation of a right secured by the Constitution or federal law and conduct by a person acting under color of state law. Individual liability requires a connection between the defendant’s actions and the alleged deprivation.

Analysis and ruling

The court explained that prisoners have a protected First Amendment interest in having properly marked legal mail opened only in their presence. It held that, when Hayes’s allegations were read liberally, he stated a cognizable First Amendment claim against all defendants based on opening his outgoing legal mail addressed to the Los Angeles County Courthouse outside his presence.

The court ordered service on Corina Lopez, Ashalla Binning, Justin Garcia, Correctional Officer Robles, and Correctional Officer Partida through the California Department of Corrections and Rehabilitation’s electronic-service pilot program. It directed the parties to follow a schedule for any dispositive motion, Hayes’s opposition, and a reply. It also allowed discovery under the Federal Rules of Civil Procedure without requiring another court order and instructed Hayes to keep the court informed of address changes and comply with court orders. The order did not decide the ultimate merits of Hayes’s claim.