Lawrence v. Borla
- Thomas Hixson
- 3:25-cv-06137
- U.S. District Court · Northern District of California
- 8
In Lawrence v. Borla, Judge Thompson allowed an Eighth Amendment claim to proceed, dismissed CDCR, and denied Lawrence’s preliminary-injunction motion.
Kmaal M. Lawrence’s case may proceed on his Eighth Amendment inadequate-living-space claim against Edward Borla and Jefferey Macomber. The California Department of Corrections and Rehabilitation was dismissed as a defendant, and Lawrence’s preliminary-injunction motion was denied.
What happened
In Kmaal M. Lawrence v. Edward Borla, et al., Lawrence, a prisoner representing himself, alleged that he had been housed with another prisoner in an unconstitutionally small cell since May 7, 2024. He sued Edward Borla, Jefferey Macomber, and the California Department of Corrections and Rehabilitation under a federal civil-rights law.
The court dismissed the Department as a defendant because it is a state agency immune from damages suits. It found that Lawrence stated a valid claim under the Eighth Amendment against Borla and Macomber based on inadequate living space and ordered that the claim be served on them. The court denied Lawrence’s request for a preliminary injunction concerning alleged retaliation and double-celling.
Judge Ina-L. Thompson issued the order. The court’s analysis says the preliminary-injunction motion was denied without prejudice, while the conclusion states simply that it was denied.
The detailed version
- Lawrence v. Borla · No. 3:25-cv-06137
- Thomas Hixson
- Dec. 4, 2025
Background
Kmaal M. Lawrence, a prisoner at Correctional Training Facility, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. The court screened the complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner complaints and dismiss claims that are frivolous, malicious, inadequately pleaded, or barred by immunity.
Lawrence named Edward Borla, the warden of Correctional Training Facility; Jefferey Macomber, the Secretary of the California Department of Corrections and Rehabilitation; and the California Department of Corrections and Rehabilitation itself. He alleged that the defendants violated the Eighth Amendment by housing him with another prisoner in a cell containing only 19 square feet. He alleged that this double-celling had continued since May 7, 2024, and that certain buildings had been used for double-celling since 2011 even though they were not built as double cells. He sought damages.
Screening Ruling
The court dismissed the California Department of Corrections and Rehabilitation because it is a state agency and has immunity under the Eleventh Amendment from suits seeking damages. The court held that, when liberally construed, Lawrence’s allegations stated an Eighth Amendment claim against Borla and Macomber for inadequate living space. The court therefore ordered service of the complaint on those two defendants through the prison system’s electronic service program, with service by the United States Marshals Service if necessary.
Preliminary-Injunction Motion
Lawrence moved for a preliminary injunction to preserve the status quo. He alleged that officers had used or threatened disciplinary action to force him to accept double-celling and that other prisoners who filed similar lawsuits had been threatened with transfer. The court noted that the motion appeared identical to motions filed in related cases and did not provide information specific to Lawrence.
A preliminary injunction is an extraordinary remedy. The court explained that Lawrence had to show a likelihood of success on the merits, likely and immediate irreparable harm, that the balance of hardships favored him, and that an injunction would serve the public interest. The court found that he had not made these showings. It also found that threatening to place him in a double cell was not an adverse action supporting retaliation because the complaint indicated that he was already in a double cell. In addition, the court said it lacked jurisdiction to order relief against unnamed officers who were not defendants in this action and that Lawrence had not alleged involvement by Borla or Macomber in the alleged retaliation.
The analysis states that the preliminary-injunction motion was denied without prejudice. The numbered conclusion states that the motion was denied. The order also set procedures for service, answers, discovery, and future dispositive motions.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.