Calvin v. Santoro

Background

Henry Rene Calvin, identified as a self-represented state prisoner at Corcoran State Prison, filed a complaint under 42 U.S.C. § 1983 against Kelly Santoro, identified as the warden of Salinas Valley State Prison, and the California Department of Corrections and Rehabilitation. The court had separately granted Calvin’s request to proceed without paying the filing fee.

Calvin alleged that, while housed at Salinas Valley State Prison on December 10, 2024, he was placed on suicide watch after a mental breakdown. He alleged that prison officials housed him in a holding cell with a mattress, blanket, and suicide safety smock rather than in a mental-health crisis bed. He asserted that the corrections department was required to provide safe and adequate shelter, including beds and reasonably sanitary bedding. He claimed that being forced to sleep on a mattress on the floor violated the Eighth Amendment or due process. He sought $250,000 in damages and asked to participate in reforming the prison grievance process.

Screening analysis

Because a prisoner sued governmental defendants, the court screened the complaint under 28 U.S.C. § 1915A. To state a claim under § 1983, a plaintiff must plausibly allege both a violation of a constitutional or federal-law right and a violation committed by a person acting under state authority.

The court explained that an Eighth Amendment conditions-of-confinement claim requires allegations showing an objectively serious deprivation and that the prison official knowingly disregarded a substantial risk to the prisoner’s health or safety. The court found Calvin’s allegations insufficient as currently written for two reasons. First, the allegation that he received a mattress, blanket, and suicide safety smock instead of a crisis bed did not plausibly show that he lacked safe and adequate shelter or reasonably sanitary bedding. Second, even if the complaint alleged that a crisis bed was necessary for his safety during the mental breakdown, it did not state how long the alleged deprivation lasted.

The court also found that the complaint did not adequately state a claim against Santoro. It did not allege that Santoro was personally involved in the alleged deprivation or engaged in wrongful conduct that caused it. The court further held that the California Department of Corrections and Rehabilitation was not a “person” subject to suit under § 1983.

Finally, the court found that Calvin’s general references to due process, including allegations about unfair hearings after a “115 (write up)” and other abuses of power, were too vague and conclusory. The complaint did not identify a specific protected liberty or property interest, the government’s deprivation of that interest, or the process that should have been provided. The court stated that a challenge to prison discipline would require facts about the charge and disciplinary proceedings, including the claimed lack of required constitutional protections and any resulting deprivation of a liberty interest of real substance.

Disposition

The court found that the complaint presently failed to state any cognizable claim for relief. It granted Calvin leave to file an amended complaint by December 5, 2025. The amended complaint had to use the case caption and number in the order and include the words “AMENDED COMPLAINT” on its first page.

The court explained that an amended complaint would replace the original complaint, so claims and defendants omitted from the amended complaint would no longer be part of the case. It warned that if Calvin did not timely amend, or if the amended complaint did not correct the identified defects, the court could issue an order reassigning the case to a district judge with a recommendation that the action be dismissed. The court did not dismiss the action in this order.