Young v. County of Alameda

Background

Walter Lee Young, an inmate at Santa Rita Jail, filed this civil-rights action under 42 U.S.C. § 1983 without a lawyer. The court had previously screened his original complaint under the prisoner-screening statute, 28 U.S.C. § 1915A, dismissed it, and allowed amendment in part. Young then filed a First Amended Complaint.

The First Amended Complaint referred to allegations that Young had been sexually, mentally, emotionally, and physically assaulted, targeted, discriminated against, locked down, and illegally strip-searched. It did not provide facts supporting those allegations. Young again named only the County of Alameda, Santa Rita Jail, and the Alameda County Sheriff’s Office as defendants.

Young also referred to a related class action involving alleged mistreatment of inmates with mental-health diagnoses at Santa Rita Jail. That action resulted in a consent decree. The court had previously dismissed, without leave to amend, Young’s claims alleging violations of that consent decree and explained that those claims must be pursued with class counsel. The court again stated that Young could not pursue claims in this case that duplicate claims raised in that class action.

Court’s analysis

Because Young is a prisoner seeking relief from governmental entities, the court screened the First Amended Complaint under 28 U.S.C. § 1915A. At screening, the court must identify legally cognizable claims and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek monetary relief from an immune defendant. The court also said it must read filings by people without lawyers liberally.

The court concluded that Young had again failed to state a cognizable claim because he listed alleged harms without providing supporting facts. If he amends, he must explain what happened, when it happened, who caused the harm, and why the facts establish a legal claim.

The court also concluded that Young had not identified a proper defendant. To pursue claims against the government entities, he would need to identify, for each defendant and each claim, an unconstitutional policy or practice that caused the alleged deprivation. Alternatively, he could identify individual officers who allegedly caused him harm. The court assumed for screening purposes that Young had exhausted his administrative remedies.

Ruling and next steps

The court dismissed the First Amended Complaint with leave to amend only as to claims stated against proper defendants and not concerning violations of the consent decree in the related class action. The court allowed Young 35 days from the filing of the order to file a Second Amended Complaint. That complaint must use the required caption and case number, state facts showing entitlement to relief for each claim, and identify a proper defendant for each claim.

The court warned that failing to file a compliant amended complaint within the allotted time would result in a finding that further amendment would be futile and dismissal of the action. It also stated that failing to prosecute the case or comply with court orders could result in dismissal under Federal Rule of Civil Procedure 41(b). Separate payment instructions directed the prison trust-account office to make filing-fee deductions, but the opinion does not state the amount of the initial partial fee.