Nava v. Newsom

Background

Luis Alberto Alarcon Nava, a prisoner at San Quentin Rehabilitation Center, filed a civil-rights complaint under 42 U.S.C. § 1983 while representing himself. The court had allowed him to proceed without paying the filing fee and screened the complaint under 28 U.S.C. § 1915A.

Nava alleged that, in April 2017, he experienced a severe trauma episode in the prison yard. According to the complaint, a correctional officer laughed at him and yelled obscenities instead of summoning medical help. Several correctional officers then handcuffed him, stood him up, and pushed him through the yard. Nava alleged that one officer hit him in the face while he was handcuffed, causing his face to strike metal bars and injuring his head, ear, and wrist. He was later treated at a hospital for a fractured left wrist, but he alleged that the required surgery was not provided.

Nava named only Governor Gavin Newsom, alleging that Newsom was responsible because of his position overseeing California prisons. The complaint also included an attached petition concerning a 2012 conviction in Kern County.

Court’s analysis

The court determined that Nava’s allegations presented potential claims for excessive force and deliberate indifference to serious medical needs under the Eighth Amendment. The court did not decide whether those claims were true or whether Nava would ultimately prevail.

Instead, the court found that the complaint did not adequately allege that the claims were timely. Section 1983 borrows California’s two-year statute of limitations for personal-injury claims. The court explained that California law can provide up to two additional years of tolling for qualifying imprisonment, giving Nava a maximum of four years under the rules discussed in the order. Based on the alleged April 2017 events, that period would have expired in April 2021, while the complaint was filed in March 2025. The court stated that Nava might be able to provide facts supporting additional tolling, including facts concerning when he knew or had reason to know the basis for his claims, although the court considered that possibility doubtful.

The court also found that Nava did not identify the correctional officers who allegedly assaulted him or denied him care, or the medical officials who allegedly denied his wrist surgery. An amended complaint needed to identify each defendant, describe that defendant’s specific actions, and address whether the claims against each defendant were timely. The court explained that a person generally cannot be held liable under § 1983 without personal involvement in the alleged constitutional violation.

The court separately dismissed the claim against Newsom because supervisors are not liable under § 1983 solely because they supervise other officials. The complaint did not allege that Newsom participated in or directed the conduct, or knew of the violations and failed to prevent them. The court also directed that any request for relief concerning the 2012 conviction be filed as a separate habeas petition in the Eastern District of California, where Nava was convicted.

Disposition

Judge Rita F. Lin dismissed the complaint with leave to file an amended complaint by December 15, 2025. The amended complaint had to use the required caption and case number, state that it was a first amended complaint, identify all claims and defendants, and include all allegations because it would replace the original complaint. The court warned that failure to file a proper amended complaint or comply with the order could result in dismissal under Federal Rule of Civil Procedure 41(b) for failure to prosecute.