Reed v. Harrington
- Thompson
- 3:25-cv-03511
- U.S. District Court · Northern District of California
- 3
In Cuevas Reed v. Harrington, Judge Thompson dismissed Reed’s civil-rights case during screening because the complaint failed to state a claim.
Cuevas Reed’s civil-rights case was dismissed at the required prisoner-complaint screening stage; the order also directed entry of judgment and closure of the file.
What happened
In Cuevas Reed v. Harrington, Cuevas Reed, who was detained at West County Detention Facility, sued under a federal civil-rights law. He alleged that Deputy Harrington placed him on lockdown, that classification staff delayed speaking with him, and that the events caused emotional distress and involved racial discrimination.
The court ruled that the complaint did not state a claim. It said that a short lockdown or segregation does not usually deprive a person of a constitutionally protected liberty interest, and Reed provided no facts showing that the treatment was racially motivated or that people of another race were treated differently.
The court dismissed the case for failure to state a claim, denied permission to amend because amendment would be futile, directed the Clerk to enter judgment and close the file, and stated that the order resolved ECF 2 and 5. Judge Thompson signed the order.
The detailed version
- Reed v. Harrington · No. 3:25-cv-03511
- Thompson
- Sept. 26, 2025
Background
Cuevas Reed, a person detained at West County Detention Facility in Contra Costa County, filed a civil-rights action under 42 U.S.C. § 1983. His complaint was subject to screening under 28 U.S.C. § 1915A, which requires a court to review a prisoner’s complaint against a governmental entity or officer and dismiss claims that are frivolous, fail to state a claim, or seek money from an immune defendant. The court separately granted Reed’s application to proceed without paying the filing fee.
Reed alleged that Deputy Harrington placed him on lockdown on April 1, 2025. He asked to speak with classification staff, and a person identified as John Doe from classification staff spoke with him on April 3. According to the complaint, the staff member said Reed was on lockdown and under investigation because he was acting as a “GP” prisoner, and asked whether Reed wanted to remain at West County Detention Facility, go to Martinez Detention Facility, or participate in programming with the group. Reed was later released for free time. He alleged that the events caused him emotional distress and that he was discriminated against because of his race.
Court’s analysis
The court explained that a § 1983 claim requires allegations showing both a violation of a constitutional or federal statutory right and action by a person acting under state law.
The court held that the complaint failed to state a claim. It determined that lockdown or segregation for a short period does not implicate a constitutionally protected liberty interest because it is not a deprivation of “real substance.” The court also found that Reed alleged no facts supporting his racial-discrimination assertion. In particular, he did not describe how a detainee of another race was treated or allege facts showing that the defendants acted because of his race.
The court considered whether Reed could amend the complaint but concluded that he could not state a claim through amendment. It therefore found amendment futile and did not allow leave to amend.
Disposition
The court dismissed the case for failure to state a claim upon which relief may be granted. It directed the Clerk to enter judgment and close the file. The order stated that it resolved ECF 2 and 5. Judge Ina L. Thompson signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.