Murillo v. West County Detention Facility

Background

Eric Murillo, a detainee at Martinez Detention Facility, filed a civil-rights complaint under 42 U.S.C. § 1983 without a lawyer. The court had allowed him to proceed without paying the filing fee and screened the complaint under 28 U.S.C. § 1915A.

Murillo alleged that in May 2025 he asked for his cell window to be cleaned and sprayed because of spiders. Custody staff told him the work would eventually be done but that facility services was backed up. He reported killing three spiders and having spider bites, but was told that staff could not do anything and that the request had been sent to facility services. Several days later, another spider landed on him. He said he had arachnophobia and that staff ignored his requests for help. Medical personnel treated him for spider bites, but he later developed a bump on his chest. He was eventually moved to another cell.

Screening Analysis

The court explained that a pretrial detainee challenging confinement conditions must show that the conditions amounted to punishment in violation of the Fourteenth Amendment’s Due Process Clause. The court also noted that denying basic necessities, including sanitation, can violate constitutional rights.

The court held that Murillo’s allegations did not state a legally sufficient claim. Specifically, he had not shown that the spiders constituted punishment by jail officials or that they denied him the basic necessities of life. The court therefore dismissed the complaint with leave to file an amended complaint.

Request for Counsel

Murillo also asked the court to appoint counsel. The court explained that there is no constitutional right to appointed counsel in a civil case. A court may request counsel for a person unable to afford one only in exceptional circumstances, considering both the likelihood of success and the person’s ability to present the claims without a lawyer given the legal issues’ complexity.

Judge Rita F. Lin denied the request without prejudice. The court found that the case did not present complex legal issues, that Murillo had been able to pursue this case and other cases, and that it was too early to determine the likelihood of success.

Disposition and Instructions

The motion to appoint counsel was DENIED without prejudice. The complaint was DISMISSED with leave to file an amended complaint by December 22, 2025. The amended complaint must use the caption and case number specified by the court, state “FIRST AMENDED COMPLAINT” on its first page, use the court’s form, include all claims and defendants Murillo wishes to pursue, and not incorporate the earlier complaint by reference.

The court warned that failure to file a proper amended complaint or comply with the order could result in dismissal of the action under Federal Rule of Civil Procedure 41(b) for failure to prosecute. The order also required Murillo to keep the court informed of any address change and comply with court orders or request extensions.