Nadler v. Borla

Background

Ryan Matthew Nadler, a prisoner at Correctional Training Facility, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. He named Edward Borla, identified as the Warden of Correctional Training Facility, and the California Department of Corrections and Rehabilitation (CDCR). The case was related to an earlier case involving similar or identical allegations. Nadler alleged that the defendants violated the Eighth Amendment by housing him in an unconstitutionally small cell and sought damages.

The court reviewed the complaint under 28 U.S.C. § 1915A, which requires federal courts to screen prisoner complaints seeking relief from governmental entities or employees. At screening, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also stated that complaints filed without a lawyer must be read liberally, while still containing enough factual allegations to make a claim plausible.

Analysis

The court dismissed CDCR as a defendant because it is a state agency and therefore has Eleventh Amendment immunity from a damages suit. The court did not dismiss the claim against Borla. It explained that although the Constitution does not require comfortable prisons, the Eighth Amendment requires prisons to provide the basic necessities of civilized life. Reading Nadler’s allegations liberally, the court found that he stated a legally recognized Eighth Amendment claim against Borla for inadequate living space.

The opinion also noted that Nadler had filed a separate addendum seeking to add additional claims, but the order does not state that those additional claims were accepted or served.

Disposition and Case Status

The court found that Nadler had stated a cognizable Eighth Amendment claim against Borla. It ordered service on Borla through CDCR’s electronic service program for prisoner civil-rights cases. The order describes procedures for waiver of service and, if necessary, service by the United States Marshals Service. Defendants must answer under the Federal Rules of Civil Procedure, subject to the timing provisions described in the order.

Briefing is currently stayed while the court decides whether to set a bellwether case. If the motion to set a bellwether case is granted, the related non-bellwether cases will be stayed; if it is denied, the court will set briefing schedules in the related cases. The court also granted Nadler’s request to proceed without paying the filing fee by separate order. Nadler must serve future communications on the defendants or their counsel, keep the court informed of address changes, and prosecute the case. The judge’s name is not provided in the opinion.