Murillo v. West County Detention Facility Medical

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. He sued West County Detention Facility Medical and sought to impose liability on the county jail under Monell v. Department of Social Services.

Murillo alleged that he told medical personnel at the jail about a shoulder injury and pain. He said the pain caused sleep deprivation because of the thin mattress provided to him, and that the resulting headaches and migraines made it difficult to perform simple tasks such as eating and exercising. He further alleged that he repeatedly sought help from medical personnel but did not receive an adequate response.

Screening and Analysis

Because Murillo sought relief from a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. The court was required to identify claims that were legally sufficient and dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also stated that it must read complaints filed without a lawyer liberally, but that a complaint still must include enough factual matter to make a claim plausible.

For a claim under 42 U.S.C. § 1983, a plaintiff must allege that a constitutional or federal-law right was violated and that the violation was committed by a person acting under state authority. To hold a municipality liable under Monell for governmental inaction or omission, a plaintiff must identify a constitutional right, a municipal policy, deliberate indifference to that right, and a causal connection between the policy and the constitutional violation. If no specific policy is identified, the plaintiff must provide evidence of an unconstitutional practice or custom. The court stated that a single incident is not enough to establish Monell liability.

The court concluded that Murillo had not alleged that the county jail had a policy, practice, or custom that caused the alleged constitutional violation. It held that Murillo could not establish a Monell claim merely by stating that he received inadequate medical care. The court said he needed to identify the rights allegedly violated by the agency’s policy or practice, provide details about that policy or practice, and explain how it specifically caused his injuries.

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, include the words “FIRST AMENDED COMPLAINT” on its first page, and use the court’s form. It must include all claims and defendants Murillo wishes to pursue because an amended complaint replaces the earlier complaint; it may not incorporate the earlier complaint by reference.

The order states that failure to file a proper amended complaint or comply with the instructions will result in dismissal of the action under Federal Rule of Civil Procedure 41(b) for failure to prosecute, without further notice. It also requires Murillo to keep the court informed of any change of address and comply with court orders or request an extension of time.