Godoy v. Brown

Background

Maurice Godoy, an inmate at the California Substance Abuse Treatment Facility, proceeded without a lawyer and filed a civil-rights action under 42 U.S.C. § 1983. The court was reviewing his amended complaint under the prisoner-screening statute, 28 U.S.C. § 1915A(a). That statute requires the court to identify claims that can proceed and dismiss claims that are frivolous, fail to state a claim, or seek money from an immune defendant.

Godoy’s amended complaint alleged a wide range of conduct, including retaliation for filing grievances, inadequate medical care, unconstitutional prison conditions, violations of the Americans with Disabilities Act, denial of court access, sexual assault, false accusations, property deprivation, failure to protect him from harm, and conspiracy. The allegations concerned events over several years at more than one prison. The complaint named more than 30 defendants and again sought to add other inmates as co-plaintiffs.

Amended-Complaint Screening

The court held that the amended complaint still violated Federal Rule of Civil Procedure 20(a)(2), which permits multiple defendants to be joined in one case only when the claims arise from the same transaction or series of events and involve a common legal or factual question. The court therefore dismissed the amended complaint with leave to amend.

The court instructed Godoy to select claims that satisfy the joinder requirements and to present only those claims in this case. It also instructed him to comply with venue requirements. Claims based on events at California Institute for Men or Lancaster State Prison were identified as belonging in the Central District of California, while claims based on events at Mule Creek State Prison or the Substance Abuse Treatment Facility were identified as belonging in the Eastern District of California. The court stated that this action could provide relief only for events that occurred within the Northern District of California.

The court also denied Godoy’s renewed request to add additional inmates as co-plaintiffs. It told him to file a second amended complaint containing a brief statement of the facts supporting each claim, identifying the defendant involved, and avoiding allegations about constitutional violations suffered by other prisoners.

Motion for Other Relief

The court denied Godoy’s motion for declaratory judgment, a preliminary injunction, a restraining order, and partial summary judgment.

Godoy’s request for partial summary judgment concerned the liability of officials at California Institute for Men. The court explained that summary judgment was premature because Godoy had not yet filed a complaint stating claims that could proceed and service on the defendants had not been authorized. The court stated that, if the action passed screening, it would order service and establish a schedule for discovery and later case-dispositive motions. The discussion stated that denial of the summary-judgment request would generally be without prejudice to refiling at the appropriate stage, but the order’s conclusion simply denied the motion.

The requested preliminary injunction sought medical assistance, disability accommodations, follow-up treatment, removal of certain disciplinary documents or stay-away orders, prison transfers, and a single cell. Godoy also sought a restraining order concerning medical care and disability accommodations. The court explained that a preliminary injunction generally requires notice to the opposing party, and the defendants had not been given notice. It further found that Godoy had not shown the facts needed for an emergency restraining order without notice and had not yet stated claims that could proceed. Relief concerning events at California Institute for Men also had to be sought in the Central District of California.

The court noted that Godoy’s motion did not specify what declaration he wanted. It stated that, if he generally sought declaratory relief, he could request it in his second amended complaint rather than through a separate motion.

Result and Next Step

The court dismissed the amended complaint with leave to amend and gave Godoy 28 days from the filing of the order to submit a second amended complaint. The new complaint had to use the case caption and number specified by the court and state “SECOND AMENDED COMPLAINT” on its first page. The court warned that failure to file a proper amended complaint within that period would result in dismissal of the action without further notice. Judge Naas S. Gilliam, Jr. ordered that the relevant motions and amended complaint be terminated from the docket.