Candalria v. Jonsen

Background

Robert Ben Candalria, an inmate at the Santa Clara County Jail proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against Santa Clara County and three jail employees. The complaint also named nine additional inmates as plaintiffs, but only Candalria signed it. The court stated that Candalria’s application to proceed without paying the filing fee was granted in a separate order.

Court’s Analysis

The court conducted the preliminary screening required for prisoner cases seeking relief from governmental entities or employees. It explained that a complaint must provide enough factual information to give defendants fair notice and state a legally plausible claim. To proceed under Section 1983, a plaintiff must allege both a violation of a federal right and conduct by a person acting under state law.

The court focused on improper joinder. Federal Rule of Civil Procedure 18 allows multiple claims against one opposing party, while Rule 20 permits multiple defendants to be joined only when the claims arise from the same transaction, occurrence, or series of occurrences and share a legal or factual question. The court found that the complaint combined unrelated claims, including allegations that Sergeant Mosquera made false statements in grievance responses; that Adreanna Dominguez implemented a policy denying in-person law-library access; and that County policies caused inadequate time outside cells, ineffective grievance procedures, delayed and opened legal mail, denial of court access, and placement in restrictive housing without process. The court found that these claims involved different incidents, defendants, and alleged constitutional violations.

The court also addressed the nine additional inmate plaintiffs. They had not signed the complaint as required by Federal Rule of Civil Procedure 11(a). The court ruled that Candalria could not represent them because he is not a lawyer. They could remain in the case only if they signed the amended complaint and their claims arose from the same transaction or occurrence as Candalria’s claims. Otherwise, they could file separate complaints.

Order

The court ordered Candalria to file an amended complaint by January 6, 2026. The amended complaint must use the caption and civil case number specified in the order, include the words “COURT-ORDERED FIRST AMENDED COMPLAINT” on the first page, and include all claims he wishes to pursue because an amended complaint replaces the original complaint. The court did not dismiss the action in this order. It stated that failure to file a compliant amended complaint could result in dismissal for failure to prosecute under Federal Rule of Civil Procedure 41(b), and that such dismissal would be without prejudice to filing the misjoined claims in separate cases. The order was signed by United States District Judge Jacqueline Scott Corley.