Robert John Stockton v. Smith, et al.

Background

Robert John Stockton, an inmate at California State Prison–Corcoran, brought this action without a lawyer under 42 U.S.C. § 1983 against former Pelican Bay State Prison warden Smith and correctional counselors Juneau and Durham. He alleged that the defendants were deliberately indifferent to his safety, in violation of the Eighth Amendment, when they placed inmate Winson in Stockton’s Restricted Custody General Population group in May 2024.

Restricted Custody General Population, or RCGP, was an increased-security housing setting for inmates who faced safety concerns in the general population. Prison officials assigned RCGP inmates either to walk alone or to groups after reviewing factors such as documented enemies, gang affiliations, disciplinary history, and the inmate’s stated safety concerns.

On May 23, 2024, the defendants reviewed Winson’s records and approved him for Group 6, which included Stockton. The records showed no documented enemy relationship between Winson and Stockton or between Winson and other Group 6 inmates, and showed that Stockton and Winson were affiliated with the same security-threat group. Stockton was not consulted before Winson’s placement. On May 31, 2024, Winson pulled a knife during an altercation with Stockton in the yard. Stockton wrestled the knife away and stabbed Winson. Stockton was later found guilty of an institutional rules violation accusing him of attempting to murder Winson.

Surreply request

Stockton asked for permission to file a surreply, which is an additional filing after a reply brief. He sought to submit an inmate orientation book and a declaration concerning RCGP procedures and conditions. The court denied the request because the defendants’ reply did not submit new evidence, Stockton’s proposed filing did not cite a newly published relevant judicial opinion, and Federal Rule of Civil Procedure 56(d) did not provide a basis for filing the surreply six months after his opposition. The court also found that Stockton had not shown why he could not timely present the information, including because he had waited several months to serve discovery requests.

Exhaustion of administrative remedies

The Prison Litigation Reform Act requires prisoners to complete available prison grievance procedures before bringing certain federal claims about prison conditions. The defendants argued that Stockton had not exhausted those procedures because prison officials had rejected his grievance as anticipatory, meaning that the event forming the basis of the grievance had not yet been formally finalized.

Stockton’s grievance accused the defendants of endangering him by placing Winson in his group. The prison’s Office of Grievances rejected it, but the Office of Appeals later denied the grievance and stated that the decision exhausted Stockton’s administrative remedies and that no further remedy applied.

The court denied the defendants’ motion for summary judgment based on failure to exhaust. It reasoned that the Office of Appeals’ use of the word “denied,” its statement that the remedies were exhausted, and its statement that no further remedy was available reasonably informed Stockton that he had completed the process. The court also held that Stockton was not required to file a new grievance after Winson’s disciplinary proceeding ended.

Eighth Amendment claim

To establish an Eighth Amendment failure-to-protect claim, a prisoner must show an objectively serious risk of harm and that the officials actually knew of and disregarded that risk. The court emphasized that deliberate indifference requires more than negligence and that officials must have drawn the inference that a substantial risk existed; it is not enough that they should have known of the risk.

The court held that Stockton had not shown a genuine dispute of material fact on the required knowledge element. The record showed that the defendants reviewed Winson’s classification information, enemy information, security-threat-group affiliations, and disciplinary history. The record also showed that Winson had no documented enemy concerns with Group 6 inmates, had been free of disciplinary or violence incidents for a year before the placement, had previously participated in RCGP groups without incident, had asked to join Group 6, and was affiliated with the same security-threat group as Stockton. Stockton had not told the defendants or other correctional officers about his safety concerns before the May 31 incident.

The court rejected Stockton’s argument that the defendants should have known he faced a serious risk. It also rejected his argument that failing to consult him before placing Winson in Group 6 violated the Eighth Amendment, noting that the cited prison handbook did not require officials to obtain consent or feedback from inmates already assigned to the group and that the Eighth Amendment imposed no such requirement.

Qualified immunity and disposition

Qualified immunity generally protects government officials from having to stand trial when their conduct did not violate a constitutional right or the right was not clearly established. Because the court found no Eighth Amendment violation, it ended the qualified-immunity analysis without addressing the second question.

The court denied Stockton’s request for leave to file a surreply and granted the defendants’ motion for summary judgment. Judgment was entered for the defendants and against Stockton, and the Clerk was directed to close the case.