Nubbs v. SAN MATEO COUNTY SHERIFF DEPUTY COLEMAN

Background

Plaintiff Shea Aaron Nubbs, an inmate at San Mateo County Jail, filed this pro se (self-represented) civil rights complaint under 42 U.S.C. § 1983, which allows individuals to sue state or local government officials for violations of federal constitutional rights. He named San Mateo County Sheriff's Deputy Coleman and unidentified additional correctional officers as defendants. His separate application to proceed without paying court fees (in forma pauperis) was granted in a separate order.

Allegations

Nubbs alleges that Deputy Coleman and several coworkers assaulted him. Specifically, he claims Coleman suspended him in the air by his handcuffs, swung his head into stairs, a riot shield, and doorframes, broke his wrist in an elevator, and squeezed his genitals. He further alleges he was then left overnight in a holding cell while bleeding from his head and with a broken wrist, receiving inadequate medical attention and no pants, socks, or shoes.

Legal Standard Applied

Federal law (28 U.S.C. § 1915A) requires courts to screen complaints filed by prisoners against government officials before allowing the case to proceed. The court must dismiss claims that are frivolous, malicious, fail to state a viable legal claim, or seek money from a defendant who is immune from suit. Pro se complaints are read generously.

To state a claim under § 1983, a plaintiff must allege: (1) a violation of a right guaranteed by the U.S. Constitution or federal law, and (2) that the violation was committed by someone acting under the authority of state law (such as a sheriff's deputy).

Court's Analysis

The court noted it was unclear from the complaint whether Nubbs had been convicted at the time force was allegedly used. This distinction matters legally: pretrial detainees (those awaiting trial) are protected from excessive force by the Fourteenth Amendment's Due Process Clause, while convicted prisoners are protected by the Eighth Amendment's prohibition on cruel and unusual punishment. The court found that under either standard, Nubbs's allegations were sufficient to state a plausible constitutional claim against Coleman for use of excessive force.

The court also noted that Nubbs appeared to want to sue additional, unnamed officers, but because they are not identified by name, they are treated as "Doe" defendants. The court instructed that to add any of them to the lawsuit, Nubbs must file an amended complaint identifying each defendant by name and explaining their specific involvement.

Disposition

The court issued an Order of Service, directing the U.S. Marshal to serve the complaint and summons on Deputy Coleman at the San Mateo County Jail without prepayment of fees. A courtesy copy was also to be mailed to the San Mateo County Counsel's Office.

The court set the following briefing schedule: - Coleman must file a motion for summary judgment or other dispositive motion by December 4, 2026, supported by factual documentation and relevant incident records. - Nubbs must file any opposition by January 8, 2027. - Coleman must file a reply by January 22, 2027. - The motion will be decided without a hearing unless the court later orders one.

The court also ordered the clerk to correct the docket to reflect Coleman as the sole named defendant, removing "San Mateo County Sheriff Correctional Officers," "San Mateo County Jail," and "McGuire Correctional Facility" as listed defendants.

Discovery (the process of exchanging information and evidence) may proceed under the standard Federal Rules without a special court order.

Notes on Anonymization

No party name anonymization issues were identified. Plaintiff is identified by full name in the caption and throughout the opinion.