Valeriano-Delacruz v. Brazelton

Background

Plaintiff Alfonso Valeriano-Delacruz, a California state prisoner proceeding without counsel (pro se), filed a complaint under 42 U.S.C. § 1983 — a federal civil rights statute that allows individuals to sue state officials for violations of constitutional rights — against several supervisory employees of the California Department of Corrections and Rehabilitation (CDCR). The named defendants are: Paul Brazelton, identified as the Warden of CTF-Soledad; Michele D. Tomas, identified as Chief Medical Officer at CTF; Craig Koenig, identified as the Warden of Pleasant Valley State Prison; and I. Igbinoso, identified as Chief Medical Officer at Pleasant Valley State Prison.

Valeriano-Delacruz alleged that from 2014 to 2018 and continuing to the present, these supervisory officials were deliberately indifferent to his serious medical needs — a standard under the Eighth Amendment (the constitutional prohibition on cruel and unusual punishment) — by failing to provide proper medical equipment for self-catheterization, delaying medical treatment and diagnostic tests, and failing to provide medications. His theory of liability was that, as supervisors, the defendants were responsible for creating, promulgating, and implementing medical policies, and for ensuring prisoners received proper medical care.

Procedural Posture

The complaint came before the court for mandatory preliminary screening under 28 U.S.C. §§ 1915 and 1915A(a), which require courts to review prisoner complaints against government entities or officials and dismiss claims that are frivolous, malicious, fail to state a claim, or seek relief from an immune defendant. Pro se pleadings are to be liberally construed.

Court's Analysis

Failure to State a Claim — Lack of Specific Facts

The court found the complaint insufficient because it lacked specific facts connecting any individual defendant to any specific constitutional wrong. Under the pleading standard established in Ashcroft v. Iqbal, 556 U.S. 662 (2009), a complaint must contain enough factual matter to make a claim for relief plausible on its face — general or conclusory allegations are not enough. The court emphasized that § 1983 liability requires individualized causation: a person is liable only if they personally committed an affirmative act, participated in another's affirmative act, or failed to perform a legally required act that caused the deprivation. Citing Keates v. Koile, 883 F.3d 1228 (9th Cir. 2018), the court noted that defendants must have been integral participants in the unlawful conduct.

Supervisory Liability

The court explained that supervisory defendants cannot be held liable under § 1983 simply by virtue of their supervisory roles. Citing Iqbal, the court noted that bald or conclusory allegations of supervisory responsibility do not plausibly establish a supervisor's personal involvement in a constitutional violation. The court advised Valeriano-Delacruz to focus any amended complaint on the specific individuals who denied him help, identifying what was requested, when it was denied, and at which institution.

Venue — Pleasant Valley Defendants

The claims against defendants Koenig and Igbinoso — both associated with Pleasant Valley State Prison — were dismissed without prejudice on venue grounds. The court stated that Pleasant Valley State Prison lies within the Eastern District of California, and claims against personnel there must be filed in that district. Valeriano-Delacruz was explicitly barred from including claims against those defendants in any amended complaint filed in this action.

Statute of Limitations Warning

The court noted — without definitively ruling — that many of Valeriano-Delacruz's claims may be time-barred. Section 1983 borrows the forum state's statute of limitations for personal injury claims, which in California is two years. California law tolls (pauses) this period for two years for prisoners serving terms of less than life, giving such prisoners effectively four years to file suit. Because Valeriano-Delacruz filed suit in 2026, the court observed that claims based on events before 2022 would likely be untimely.

Disposition

The complaint was dismissed with leave to file an amended complaint on or before October 1, 2026. The amended complaint must use the same caption and case number, appear on the court's official form, be labeled "FIRST AMENDED COMPLAINT" on its first page, include all claims and defendants Valeriano-Delacruz wishes to pursue (as an amended complaint fully replaces the prior one), and contain no incorporated-by-reference material from prior filings. Failure to file a proper amended complaint by the deadline will result in dismissal of the action under Federal Rule of Civil Procedure 41(b) without further notice.