Campos v. West County Detention Facility

Background

Enrique Javier Campos, a pretrial detainee in the Contra Costa County jail, filed a civil-rights complaint under 42 U.S.C. § 1983 while representing himself. He was allowed to proceed without paying the filing fee by a separate order.

Campos alleged that Deputy Baily yelled at him while shining a flashlight in his face on June 26, 2025, and constantly harassed him, making the housing-module environment fearful and unpleasant. He also alleged that Baily ordered him to approach and accused him of hiding or snorting his medication. Campos named Sergeants Paisan, Smally, and Shepard based on their responses during the grievance process. He sought damages and an order requiring him to stay away from Baily.

Screening standard

Because Campos is a prisoner seeking relief from a governmental entity or its employees, the court screened the complaint under 28 U.S.C. § 1915A. The court was required 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 explained that a claim under § 1983 requires an alleged violation of a federal constitutional or statutory right by someone acting under state law.

Court’s analysis

For a pretrial detainee challenging confinement conditions, the relevant question is whether the conditions amounted to punishment in violation of the Fourteenth Amendment. For an excessive-force claim, the detainee must show that the force was purposely or knowingly used and was objectively unreasonable.

The court held that shining a light in Campos’s face and checking whether he took his medication did not rise to the level of a constitutional violation. The court allowed Campos to file an amended complaint explaining in more detail any other conduct by Baily that amounted to punishment without a legitimate purpose or involved unreasonable force.

The court also held that Campos could not sue the detention facility itself under § 1983 because the jail was not a “person” within the meaning of that law. The allegations against Paisan, Smally, and Shepard were insufficient because they described only participation in the grievance process. The court explained that denying a grievance, by itself, is not a constitutional violation and that liability requires personal participation in, or direction of, the alleged violation.

Disposition

The court dismissed the complaint with leave to amend. Campos must file an amended complaint within 28 days of the order’s filing date. The amended complaint must use the case caption and civil case number from the order, state “AMENDED COMPLAINT” on its first page, include every claim Campos wishes to pursue, and not incorporate the original complaint by reference. The court stated that failure to amend within the required period will result in dismissal of the case. It also directed Campos to keep the court informed of address changes and comply with court orders; failure to do so could lead to dismissal under Federal Rule of Civil Procedure 41(b).