LaBelle v. Borla

Background

Steven W. Labelle, a prisoner at Correctional Training Facility, filed a complaint without a lawyer under 42 U.S.C. § 1983. That statute allows a person to seek relief for a violation of a federal constitutional or statutory right by someone acting under state law. The court screened the complaint under 28 U.S.C. § 1915A, which requires review of prisoner complaints against governmental entities or officials.

Labelle named Edward Borla, the warden of Correctional Training Facility; Jefferey Macomber, the Secretary of the California Department of Corrections and Rehabilitation; and Connie Gipson, the former Director of Adult Institutions. He alleged that the defendants violated the Eighth Amendment by housing him with another prisoner in an unconstitutionally small double cell. He alleged that the cell had only 19 square feet of unencumbered space and that prisoners had been double-celled in certain North Yard buildings since 2011, even though those rooms were not built as double cells. He sought damages.

Screening analysis

The court explained that a prisoner complaint may be dismissed during screening if it is frivolous, malicious, fails to state a claim, or seeks money from a defendant who is legally immune from that relief. The court also explained that complaints filed without a lawyer must be read liberally, but still must contain enough factual allegations to make the claimed entitlement to relief plausible rather than speculative.

The court stated that the Eighth Amendment requires prisons to provide prisoners with the minimal civilized measure of life’s necessities, even though it does not require comfortable prisons. The court concluded that, when liberally construed, Labelle’s allegations stated an Eighth Amendment claim against the defendants for inadequate living space.

Ruling and next steps

The court ordered service through the California Department of Corrections and Rehabilitation’s electronic-service program for prisoner civil-rights cases on Edward Borla, Jefferey Macomber, and Connie Gipson. The clerk was directed to send the complaint, the order, a service-waiver form, and a summons to the department and to provide Labelle with a copy of the order.

The order set deadlines and procedures for any service waiver, answers, discovery, and motions seeking to dispose of the case. It also explained that defendants may later file a motion for summary judgment or another dispositive motion, and that a motion to dismiss based on failure to exhaust administrative remedies may be available in the circumstances described in the order. The court did not enter final judgment or decide whether Labelle ultimately proved his claim.