Crawford v. Combs

Background

Christopher Lee Crawford, a state prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983, which allows claims for certain constitutional violations by state officials. His amended complaint alleged that officials at Pelican Bay State Prison were deliberately indifferent to his safety needs during an April 13, 2016 incident involving questions about whether he wanted placement in a Special Needs Yard. The court previously found a safety-related claim legally sufficient against Sergeant Combs and Officers Spradlin, Oviatt, and Townsend. The court had dismissed Crawford’s supervisory-liability claim against CDCR Secretary Scott Kernan.

Defendants had moved for summary judgment, asked to file confidential investigatory and medical records under seal, and asked to stay discovery. Crawford had not yet opposed the summary-judgment motion. Instead, he moved for leave to supplement his amended complaint and requested a second extension of time to file his opposition.

Motion to Supplement

The proposed supplemental complaint was 61 pages long and included 90 pages of exhibits. It asserted new claims involving alleged First Amendment retaliation, Fifth Amendment due-process violations, Eighth Amendment violations, and defamation, slander, and libel. The proposed claims concerned events at California State Prison–Sacramento in 2018 and 2019 and named 11 new defendants. The proposal did not mention the four original defendants from Pelican Bay and did not relate the new allegations to the Pelican Bay incident.

Applying Federal Rule of Civil Procedure 15(a)(2), which generally provides that permission to amend should be freely given when justice requires, the court denied permission here. It found that Crawford had unduly delayed because he waited until October 15, 2019, after relevant defense-motion deadlines had passed and shortly before his opposition deadline. The court said the timing suggested bad faith.

The court also found the proposed amendment futile. In this context, futile means that allowing the amendment would not properly advance a viable case in the existing action. The court concluded that the proposed claims were unrelated to the existing deliberate-indifference claim, so joining the new parties would be improper under Rule 20. It further stated that claims arising from events at California State Prison–Sacramento belonged in the venue of the Eastern District of California, and noted that Crawford could consider bringing those claims in a new civil-rights action there.

Finally, the court concluded that adding the new claims at that late stage would prejudice defendants because the deadline for dispositive motions had passed and the new allegations would require litigation of a different set of circumstances. It therefore DENIED Crawford’s motion for leave to supplement the amended complaint.

Extension of Time and Disposition

The court found good cause for Crawford’s request for a second extension to oppose summary judgment and GRANTED that request. Crawford received until 28 days from the date of the order to file his opposition. Defendants were directed to file any reply within 14 days after Crawford filed his opposition. The court cautioned that this was the second extension and that additional routine extensions should not be expected.

The court did not decide defendants’ summary-judgment motion in this order. It stated that that motion and the other remaining motions would be resolved in a separate written order. The order terminated Docket No. 51.