Galarza v. Borla

Background

Juan Carlos Galarza, a prisoner at Correctional Training Facility, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. The complaint named Edward Borla, the warden of Correctional Training Facility, and Jeffrey Macomber, the Secretary of the California Department of Corrections and Rehabilitation. Galarza alleged that the defendants violated his Eighth Amendment rights by housing him in an unconstitutionally small cell. He sought damages.

The case was related to an earlier case identified in the opinion as 25-cv-02820-TLT, which involved similar or identical allegations. The court reviewed Galarza’s complaint under the federal statute requiring screening of prisoner complaints seeking relief from governmental entities or their employees.

Court’s analysis

The court explained that screening requires dismissal of claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. It also stated that complaints filed without a lawyer must be read generously, while still providing enough factual detail to make a claim plausible. To state a claim under Section 1983, a plaintiff must allege both a violation of a federal right and action by a person acting under state law.

The court concluded that, read generously, Galarza had stated an Eighth Amendment claim against Borla and Macomber for inadequate living space. The opinion did not decide whether Galarza will ultimately prevail on that claim.

Order

The court found the Eighth Amendment claim cognizable and ordered service on Edward Borla and Jeffrey Macomber through the California Department of Corrections and Rehabilitation’s electronic-service program for prisoner civil-rights cases. The order directed the department to report within 40 days which defendants would waive service. Defendants who waive service will receive additional time to answer; defendants served by the United States Marshals Service must answer within 21 days after service. The defendants were also ordered to answer under the Federal Rules of Civil Procedure.

Briefing is currently stayed while the court decides whether to set a bellwether case. If the court grants the motion to set one, the non-bellwether cases will be stayed; if it denies the motion, the court will set briefing schedules in the related cases. The order also requires Galarza to serve his court communications on the defendants or their counsel, keep the court informed of address changes, and prosecute the case.