Baptiste v. Hatton

Background

Kenneth E. Baptiste, an inmate at California Training Facility–Central, filed this civil-rights action under 42 U.S.C. § 1983 without a lawyer. The court reviewed the complaint under the prisoner-screening statute, 28 U.S.C. § 1915A. The named defendants were Warden J. Hatton; Correctional Counselor II Martinez; Senior Psychologist Wynn; Chief of Mental Health Howlin; staff psychologist DeAntoni; cooks G. Tow, Hernandez, and Adams; senior hearing officer Lieutenant J. Marquez; and appeals coordinator J. Truett.

The complaint, read liberally, alleged that a classification committee refused to restore Baptiste’s single-cell status; mental-health personnel failed to recommend against double-celling; and prison officials assigned him to chop 600–1,200 pounds of onions daily while he was taking psychotropic medication and had chronic Hepatitis C. He also alleged violations of administrative rules, California health-and-safety laws, and California prison regulations.

Complaint Screening

To state a § 1983 claim, a plaintiff must allege a violation of a federal constitutional or statutory right by a person acting under state authority. The court held that Baptiste’s allegations were general and did not link any particular defendant to a specific act or failure to act that violated his rights. It therefore concluded that the complaint failed to state a legally recognizable § 1983 claim against the named defendants.

The court also determined that the complaint appeared to combine two unrelated groups of claims: the denial of single-cell status and the requirement that Baptiste chop onions. The court instructed that, unless the claims were related, Baptiste could pursue only one in an amended complaint in this action and could bring the other in a separate lawsuit.

The court additionally explained that § 1983 does not impose liability solely because a person supervises someone else, that denying a prison grievance generally does not by itself establish personal liability, and that violations of state law or California prison regulations generally do not independently support a § 1983 claim. The complaint was dismissed with leave to amend so Baptiste could identify what each defendant did or failed to do and present related claims together.

Emergency Relief

Baptiste sought an ex parte temporary restraining order and preliminary injunction preventing Hatton, Martinez, Howlin, and people acting for them from double-celling him. The court denied the request. It stated that a preliminary injunction generally requires notice to the opposing parties, none of the defendants had been served, and there was no operative complaint.

To the extent the request sought a temporary restraining order that could be issued before service, the court still declined to grant it. The court found that Baptiste’s declaration did not show immediate and irreparable harm. It noted that he had been double-celled since June 18, 2016, and that the record showed no problems from double-celling after April 16, 2017.

Appointment of Counsel

Baptiste requested appointed counsel, citing his inability to afford a lawyer, the complexity of the issues, limited legal training, mental illness, and psychotropic medication. The court denied the request because he had not shown the exceptional circumstances required for appointment of counsel in a civil case. The denial was without prejudice to the court appointing counsel later if circumstances warranted.

Disposition

The court denied Baptiste’s ex parte emergency request for a temporary restraining order and preliminary injunction and denied his request for counsel. It dismissed the complaint with leave to amend and ordered him to file an amended complaint within 28 days. The amended complaint had to include all claims and defendants he wished to pursue and could not incorporate the earlier complaint by reference. The court stated that failure to comply would result in dismissal of the action without further notice.