Lynch v. Wiley

Background

Antwyone Lynch, a state inmate proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against prison staff at the Correctional Training Facility. He alleged that Captain K. Wiley, Associate Warden M. Deverick, and Correctional Officers E. Vasquez and E. Forouzadeh were deliberately indifferent to unconstitutional conditions of confinement.

According to the complaint, Deverick issued a memorandum on August 27, 2025, prohibiting window coverings in cells and warning that violations could result in a Rules Violation Report. Lynch alleged that prison officials knew that multiple window panels were missing from hundreds of cells but did not replace them. He alleged that, beginning in October 2025, officials directed him to remove coverings that he had placed over missing panels to protect himself from bad weather and extreme cold. He further alleged that Vasquez threatened an additional Rules Violation Report, failed to submit the necessary work order to replace the panels, and that Lynch remained exposed to the cold from October 2025 through January 2026.

Lynch alleged that he contracted a cold, suffered an ear injury, experienced aggravated allergies, and was exposed to flies, insects, and bugs. He asserted deliberate-indifference, failure-to-protect, and negligence theories and sought compensatory and punitive damages. The opinion states that the window panels were replaced only after Lynch filed a prison appeal.

Screening and ruling

Because a prisoner sued governmental employees, the court conducted the required preliminary screening under 28 U.S.C. § 1915A. The court explained that a claim under § 1983 requires an alleged violation of a federal constitutional or statutory right by a person acting under state authority.

For an Eighth Amendment conditions-of-confinement claim, the alleged deprivation must be sufficiently serious, and the official must have a sufficiently blameworthy state of mind. The court concluded that Lynch’s allegations were sufficient to state an Eighth Amendment claim based on the defendants’ deliberate indifference to the extreme cold he allegedly experienced for approximately four months.

Orders

The court ordered service on Wiley, Deverick, Vasquez, and Forouzadeh through the California Department of Corrections and Rehabilitation’s electronic-service program. It directed the defendants to file a summary-judgment motion or another dispositive motion concerning the claims found cognizable no later than 91 days after the order was filed. A summary-judgment motion is a request for judgment without a trial when the evidence shows no genuine dispute over facts important to the case.

The court allowed discovery under the Federal Rules of Civil Procedure, set deadlines for Lynch’s response to any dispositive motion, and stated that no hearing would be held unless later ordered. It also instructed Lynch to serve his court filings on the defendants or their counsel, keep the court informed of address changes, and prosecute the case. The court stated that Lynch’s motion to proceed without paying the filing fee would be addressed in a separate order.