Vera v. Santa Cruz Sheriffs Department Corrections
- Edward Davila
- 5:18-cv-04470
- U.S. District Court · Northern District of California
- 11
In Michael J. Vera v. Eric Gouker, Judge Davila granted summary judgment to jail officials and dismissed Vera’s Fourteenth Amendment claim because he had not completed the jail’s grievance process.
Michael J. Vera’s remaining Fourteenth Amendment claim was dismissed, and defendants Eric Gouker and Jenna Baldwin obtained summary judgment.
What happened
In Michael J. Vera v. Eric Gouker, et al., Vera, who was in custody without a lawyer, claimed that officials placed him in harsh segregated housing without explanation to pressure him to resolve his criminal case. The court had allowed his Fourteenth Amendment claim about the housing conditions to proceed, but had already dismissed his claim about lost property.
The defendants presented evidence that Vera filed two grievances about his housing but did not take either grievance through the jail’s final appeal level. Vera did not oppose the motion or provide evidence that the grievance process was unavailable to him. The court therefore found that he had not completed the required grievance process before filing the federal lawsuit.
Judge Edward J. Davila granted the defendants’ motion for summary judgment and dismissed the remaining Fourteenth Amendment claim for failure to exhaust administrative remedies. The court said it did not need to consider the defendants’ other arguments.
The detailed version
- Vera v. Santa Cruz Sheriffs Department Corrections · No. 5:18-cv-04470
- Edward Davila
- Dec. 6, 2019
Background
Michael J. Vera, a pretrial detainee, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983 against employees of the Santa Cruz County Sheriff’s Department. He alleged that, on June 22, 2018, he was moved from the jail’s general population to solitary confinement, placed in a cell without lights or plumbing for ten days, and deprived of his property without an incident report or explanation. He alleged that Eric Gouker and Jenna Baldwin made the decision for personal reasons and to pressure him to accept a faster resolution of his criminal case.
The court previously found that these allegations stated a Fourteenth Amendment deliberate-indifference claim concerning placement in conditions that amounted to punishment. It previously dismissed the claim concerning the random and unauthorized deprivation of property for failure to state a claim. The remaining claim was against Gouker and Baldwin.
Evidence about the housing decisions
The defendants submitted declarations and jail records. The evidence stated that a large fight occurred at the jail on June 21, 2018. Gouker investigated and received information from three independent sources that Vera had directed the fight. Gouker also learned that Vera was allegedly controlling inmates at another county jail through fear and intimidation. Gouker decided that Vera should be transferred to the Santa Clara County Jail for staff and inmate safety. When Vera returned to the Santa Cruz County Jail on July 2, 2018, he was placed in administrative segregation because of continuing safety concerns.
Vera filed a grievance on July 3, 2018, seeking placement in the general population. The response stated that he was pending transfer to a general-population unit. On July 6, while awaiting transfer, Vera sent Gouker a request form containing threats against Gouker and jail staff. Jail staff then decided to keep Vera in administrative segregation. Vera filed another grievance on July 10, 2018, and appealed it on July 15. He was moved to the general population on July 23, 2018.
The evidence also stated that Baldwin was not involved in the relevant transportation decisions, housing assignments, or grievance reviews.
Summary-judgment standard
Summary judgment is a procedure for deciding a case without a trial when the evidence shows no genuine dispute about a fact that could affect the result. The moving party must show the absence of such a dispute. The opposing party must then identify evidence that could allow a reasonable jury to rule in that party’s favor. Because Vera filed no opposition, the defendants’ factual submissions were undisputed for purposes of the motion.
Failure to exhaust administrative remedies
The Prison Litigation Reform Act requires a prisoner to complete available administrative remedies before bringing a federal action about prison conditions. This requirement is called exhaustion. The defendants had to prove both that an available grievance process existed and that Vera did not complete it.
The jail’s grievance policy allowed inmates to complain about conditions of confinement, including housing and classification decisions. If informal resolution failed, an inmate could file a grievance, receive an investigation and response, and appeal through a first level and then a second level. The second-level appeal was the final level available at the jail.
The court found that the defendants met their burden. The evidence showed that Vera filed two relevant grievances, Nos. A049433 and A020254, but did not pursue either one through the second-level appeal. Vera did not submit an opposition, a copy of the different grievance he identified in his complaint, or other evidence showing that the available grievance process was effectively unavailable to him.
Disposition
The court held that Vera failed to exhaust administrative remedies for all claims against the defendants. It therefore granted Eric Gouker and Jenna Baldwin’s motion for summary judgment. The court dismissed the Fourteenth Amendment claim against them for failure to exhaust administrative remedies. The court did not address the defendants’ other asserted grounds for summary judgment. The order terminated Docket No. 21.
Read the full 11-page opinion on CourtListener, the free public archive maintained by the Free Law Project.