Woods v. Marquez

Background

Robert Woods, a prisoner at California State Prison–Corcoran, filed this action without a lawyer under 42 U.S.C. § 1983. The complaint concerned events at Salinas Valley State Prison in May 2015. Woods alleged that, after he asked to be housed with a compatible inmate rather than an inmate selected by staff, correctional officer G. Marquez took him to a program office. Woods alleged that Marquez and correctional officer R. Cardona grabbed him, slammed him against a wall and a steel cage, and dislocated his shoulder. Woods also alleged that correctional lieutenant J. Celaya and correctional officer R. Correa supervised the use of force and refused to obtain immediate medical care.

Screening analysis

Because Woods was a prisoner suing government officers, the court screened the complaint under 28 U.S.C. § 1915A. At this stage, the court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, inadequately pleaded, or sought money from an immune defendant. The court also said it would read a self-represented plaintiff’s allegations liberally.

The court concluded that the complaint stated a cognizable excessive-force claim against Marquez, Cardona, Celaya, and Correa under the Eighth Amendment. Although Celaya and Correa allegedly did not personally apply force, the court found the allegations that they directed and supervised the force sufficient at this stage. The court also found a cognizable retaliation claim, based on the allegation that the defendants used force because Woods questioned the cell-assignment decision. Finally, the court found a cognizable Eighth Amendment medical-care claim against Celaya and Correa for allegedly failing to timely obtain medical assistance after Woods’s shoulder injury.

Order

The court stated that the complaint presented cognizable § 1983 claims against correctional officers G. Marquez, R. Cardona, and R. Correa, and correctional lieutenant J. Celaya. It ordered the clerk to issue summonses and the United States Marshal to serve those defendants without requiring Woods to prepay service fees.

The order set December 13, 2019, for defendants to file a summary-judgment motion or another motion that could resolve the case, January 10, 2020, for Woods to respond, and January 24, 2020, for any reply. It authorized discovery under the Federal Rules of Civil Procedure and gave Woods instructions concerning service of filings, updating his address, prosecuting the case, and identifying the case in future filings. It also required Woods by October 31, 2019, either to file a completed application to proceed without paying the full filing fee or to pay the $400 filing fee, warning that failure to do so would result in dismissal. This was a screening and service order, not a final decision on whether the defendants were liable.