Murillo v. Smally

Background

Eric Murillo, a detainee at Martinez Detention Facility, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. The court had allowed him to proceed without paying the filing fee and reviewed the complaint under the statute requiring early screening of complaints seeking relief from governmental entities or their officers or employees.

Murillo alleged that legal mail remained at the jail for several weeks before being sent and that another deputy opened legal mail given to him. He said he filed grievances about those matters. He also alleged that he received a disciplinary write-up for graffiti that was present before he arrived, that deputies harassed him when he tried to clean it, and that a deputy refused to exchange a broken electronic tablet.

Murillo further alleged that deputies searched his cell and reported finding a weapon. He was found guilty at a disciplinary hearing, placed in lockdown for ten days, and deprived of privileges. He maintained that the item was not a weapon and that the finding was retaliation for his grievances. He also alleged that his rights were violated during the disciplinary process. After he asked to speak with a lieutenant, he was told he was being transferred to another jail, where he was placed in administrative segregation and told the placement was because of staff at the prior jail.

Court’s Analysis

The court held that the complaint combined multiple unrelated claims against several defendants. Federal Rule of Civil Procedure 20(a)(2) generally does not allow unrelated claims against different defendants in one action. The court therefore directed Murillo to pursue claims involving a single event or related events in this case, while noting that other claims could be brought in separate actions.

The court also identified additional deficiencies. It explained that there is no general constitutional right to a prison grievance or administrative-appeal system, so allegations that grievances were not properly handled do not by themselves state a claim.

For the legal-mail allegations, the court said Murillo needed more specific facts. A deliberate delay that harms legal proceedings may support an access-to-the-courts claim, but an isolated interference with mail generally does not establish a constitutional violation without facts showing an improper motive or interference with counsel or court access. The court also explained that prisoners have a protected interest in having properly marked legal mail opened only in their presence, while mail from courts is not treated as legal mail under the authorities it discussed.

For the disciplinary allegations, the court said Murillo needed more information to state a due-process claim as a pretrial detainee. He would need to allege facts showing that the deprivation amounted to punishment or implicated a liberty interest created by a state statute or regulation containing required standards for official decisions. Without punishment or such a legally protected interest, the court said the allegations would not state a procedural due-process claim.

Disposition

The court DISMISSED the complaint with leave to file an amended complaint on or before January 23, 2026. The amended complaint must use the caption and civil case number specified in the order, say “FIRST AMENDED COMPLAINT” on its first page, use the court’s form, include every claim and defendant Murillo wishes to pursue, and not incorporate the earlier complaint by reference.

Judge Rita F. Lin warned that failure to file a proper amended complaint or comply with the order would result in dismissal of the action under Federal Rule of Civil Procedure 41(b) for failure to prosecute, without further notice. The order also required Murillo to notify the court separately of any address change and to comply with court orders or request extensions of time.