Young v. Aramark

Background

Zion Young, an inmate at the San Francisco County Jail, filed a civil-rights action under 42 U.S.C. § 1983 without an attorney against Aramark, Inc., which he identified as the jail’s food vendor. Young alleged that he found a maggot in his dinner, showed it to a deputy, vomited, and summoned a nurse. The complaint also listed Nicky Garcia and Philip Pitney as plaintiffs.

The court separately granted Young’s request to proceed without paying the filing fee. The court then screened the prisoner complaint under 28 U.S.C. § 1915A, which requires the court to identify claims that may proceed and dismiss claims that are frivolous, fail to state a claim, or seek relief from an immune defendant.

Young’s Claim

Section 1983 provides a way to seek relief for a violation of a federal constitutional or statutory right by a person acting under state law. The court explained that a jailed person alleging unconstitutional conditions must show deliberate indifference under the Eighth Amendment or, for a person not yet convicted, the Fourteenth Amendment. The court described deliberate indifference as more than negligence and involving disregard of a serious health or safety risk.

The court held that Young’s allegations did not support a reasonable inference that Aramark was deliberately indifferent. Young alleged only one isolated incident of food contamination and did not allege that Aramark had previously been told about maggots or other contamination. The court therefore found that Young had failed to state a claim capable of judicial determination and review.

Garcia and Pitney’s Claims

The court identified two problems with the claims attributed to Garcia and Pitney. Neither had signed the complaint or another filing, even though self-represented parties must personally sign filings. In addition, the complaint contained no factual allegations about either person other than that they were inmates at the jail. The court concluded that the complaint did not state claims by Garcia or Pitney that were capable of judicial review or determination.

The court stated that, if Garcia and Pitney wished to continue in the case, all three plaintiffs would have to sign an amended complaint containing facts supporting a reasonable inference that each suffered a violation of constitutional rights. The court also stated that Garcia and Pitney could instead file separate cases.

Service of Aramark

The plaintiffs had not provided a location for Aramark. Without that information, the United States Marshal could not serve the summons and complaint. The court ordered that, if the plaintiffs amended the complaint, they must provide sufficient location information for service or show cause—give a reason—why they could not do so. The court stated that failure to satisfy this requirement by the deadline would result in dismissal of the case without prejudice under Federal Rule of Civil Procedure 4(m).

Disposition

Judge Jacqueline Scott Corley ordered that the case be dismissed with leave to amend. The plaintiffs could file an amended complaint by November 25, 2025. The amended complaint had to use the caption and civil case number specified in the order, state “FIRST AMENDED COMPLAINT” on its first page, and include all claims because the plaintiffs could not incorporate the original complaint by reference. The court warned that failure to file a timely and sufficient amended complaint could result in dismissal. The court also instructed the plaintiffs to keep the court informed of address changes and comply with its orders.