Haywood v. Hant

Background

Tyshawn Leontray Haywood, an inmate in the Contra Costa County Jail, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983 against two Contra Costa County sheriff’s deputies. The court separately granted his application to proceed without paying the filing fee.

Haywood alleged that the toilet in his cell was broken for four days while he was locked in the cell. He alleged that he had to eat and breathe in the presence of fecal matter in the toilet. He further alleged that, on the fourth day, a deputy who was not named as a defendant told him to put on protective glasses and gloves and clean the feces and tissues himself. He sought declaratory relief and damages.

Screening and Analysis

Because Haywood is a prisoner seeking relief from government employees, the court screened the complaint under 28 U.S.C. § 1915A. The court explained that a claim under § 1983 requires allegations that a federal constitutional or statutory right was violated by a person acting under state authority. A plaintiff must also connect each individual defendant’s actions or omissions to the alleged violation.

The court stated that a pretrial detainee’s due-process rights are violated when confinement conditions amount to punishment. It concluded that, when read liberally, Haywood’s allegations could plausibly support a claim that the conditions in his cell amounted to punishment. However, Haywood did not allege any action, involvement, or omission by either named defendant. He did not allege facts supporting a reasonable inference that either deputy caused the toilet to break or remain broken for four days, or caused him to be instructed to clean it himself. The court therefore found that he had not stated a plausible due-process claim against the named defendants.

Ruling and Required Amendment

Judge Susan van Keulen dismissed the complaint with leave to amend. The court ordered Haywood to file an amended complaint by October 6, 2026, on the court’s complaint form, using the case caption and number specified in the order and placing the words “COURT-ORDERED FIRST AMENDED COMPLAINT” on the first page. The amended complaint will replace the original complaint, and Haywood may not incorporate the original complaint by reference; he must include all claims he wishes to pursue. The order states that failure to amend within the required time and in accordance with the order may result in dismissal of the case. The clerk was directed to mail him two civil-rights complaint forms, instructions, and a postage-paid envelope.