LaBelle v. S. Magaña

Background

Steven W. Labelle, who is incarcerated at the Correctional Training Facility, filed a complaint without a lawyer against more than a dozen correctional officers and administrators. He brought claims under 42 U.S.C. § 1983, which allows claims against state actors for violating federal rights, and related state-law claims under the court’s supplemental jurisdiction.

Labelle alleged that on December 31, 2025, Correctional Officer G. Hernandez asked him to leave his cell for a random cell search. Correctional Officer S. Magaña then ordered him to submit to a pat-down. Labelle objected, citing a pending grievance against Magaña and requesting to observe the cell search and have a sergeant present. Magaña activated his personal alarm, after which Labelle was handcuffed and his cell was searched.

Labelle further alleged that officers took him to a holding cell, required him to remove his clothing and perform cough-and-squat exercises, and took his state-issued clothing, shoes, and a tablet. Sergeant J. Gutierrez-Aparicio allegedly said the tablet was altered, issued a disciplinary report, and told Labelle he would not get it back. Labelle also challenged two disciplinary reports and a later decision to reassign him to the Hard C work and privilege group for 60 days.

Court’s analysis

Because Labelle is a prisoner suing government officers, the court screened the complaint under 28 U.S.C. § 1915A. The court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, inadequately pleaded, or sought money from an immune defendant. The court also explained that each defendant must be connected to specific misconduct because § 1983 does not impose liability merely because a person supervised someone else.

First Amendment retaliation

Labelle alleged that Magaña activated his alarm because Labelle had filed a grievance against him. The court dismissed the retaliation claim with leave to amend. To state a viable retaliation claim, Labelle must provide specific facts showing that a state actor took adverse action because of protected conduct, that the action chilled his exercise of First Amendment rights, and that the action did not reasonably advance a legitimate correctional goal. The related state-law claim was also dismissed with leave to amend.

Fourth Amendment claims

Labelle claimed that the strip search violated the Fourth Amendment, which protects against unreasonable searches and bodily intrusions, including for incarcerated people. The court dismissed the strip-search claim with leave to amend because Labelle needed to allege specific facts showing that officials intentionally used exaggerated or excessive methods and identifying how each responsible defendant caused the alleged violation. The related state-law claim was also dismissed with leave to amend.

The court dismissed the Fourth Amendment claim concerning seizure of the tablet without leave to amend. It held that prisoners do not have a Fourth Amendment claim based on the seizure, destruction, or conversion of their property. The court also noted that a separate due process property claim is unavailable when, as in California according to the opinion, an adequate state remedy exists after the property deprivation.

Fourteenth Amendment due process claims

Labelle challenged the findings of guilt on two rule-violation reports, asserting that the charges and evidence were inaccurate or fabricated and that there was insufficient evidence. He also challenged his 60-day reassignment to Hard C. The court dismissed these claims with leave to amend.

For a prison disciplinary due process claim, a prisoner must allege a deprivation of real substance, such as a punishment that inevitably affects the sentence’s duration or creates an atypical and significant hardship compared with ordinary prison life. Where those conditions apply, required protections can include written notice, time to prepare, a written decision, an opportunity to present witnesses and documents when appropriate, and a decision supported by some evidence. The court said a punitive reclassification also must satisfy these protections if it creates a deprivation of real substance.

Disposition

The court dismissed the complaint with leave to amend within 28 days. Any amended complaint must be simple and concise, use the caption and civil case number from the order, and state FIRST AMENDED COMPLAINT on its first page. The amended complaint will replace the original complaint, and claims or defendants left out of it will not be considered. The court stated that failure to file a proper amended complaint within the designated time will result in dismissal of the action.

The opinion also states that Labelle’s allegations or concerns about small cell size were dismissed without prejudice to bringing them in his pending suit concerning small cell size.