Guzman v. Jones

Background

Mayito Guzman, an inmate at California State Prison–Solano, filed this pro se civil-rights action under 42 U.S.C. § 1983 concerning events at San Quentin State Prison. The court had allowed him to proceed without paying the filing fee in a separate order and screened his complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner complaints against governmental entities or officials.

Guzman alleged that he worked at the prison’s main hospital, participated in college programs, and had been allowed to remain at San Quentin. He said that, in February 2019, Lieutenant D. Dorsey authored a vague report stating that Guzman was disrupting the housing unit and influencing other inmates to assault others. Guzman alleged that the report led to an unexpected transfer and prevented him from challenging the report.

According to Guzman, the transfer removed him from his job and college and rehabilitative programs, affected his ability to obtain parole, and could affect his ability to earn credits. He alleged that prison officials targeted and retaliated against him because of his Hispanic ethnicity and because the region of his commitment offense was in Northern California. He claimed violations of the Equal Protection Clause and the Due Process Clause.

Court’s Analysis

To state a claim under Section 1983, a plaintiff must allege both a violation of a federal constitutional or statutory right and action by a person acting under state authority. The court found that Guzman had not linked any defendant to the alleged constitutional violations. It was unclear how Correctional Counselor Jones, Associate Warden Samara, and Warden Davis participated in the transfer decision or the issuance of the report.

The court explained that Section 1983 does not impose liability simply because a person supervises someone who allegedly violated a plaintiff’s rights. A supervisor must have a specific causal connection to the alleged violation, such as causing it, failing to train or supervise personnel, responsibility for a relevant policy or custom, or knowing about misconduct and failing to prevent it. The court also explained that merely denying a prison grievance generally does not make an official personally liable for the underlying constitutional violation.

The court provided additional guidance concerning Guzman’s equal-protection and due-process theories. For an equal-protection claim, he would need to identify similarly situated prisoners treated differently and allege facts supporting discriminatory intent. For a due-process claim, the court noted that prisoners generally have no constitutional right to remain in a particular institution and that a prison transfer does not by itself violate due process or equal protection, even when the transfer is disciplinary or to a less favorable institution.

Disposition

The court dismissed the complaint with leave to amend. It ordered Guzman to file an amended complaint within 28 days, naming each person involved in each alleged violation and explaining what each person did or failed to do. The amended complaint had to include all claims and defendants Guzman wished to pursue and could not add unrelated claims. The court stated that failure to file a compliant amended complaint within the deadline would result in dismissal of the action without further notice. Judge Haywood S. Gilliam, Jr. signed the order.