Saddozai v. Bolanos

Background

Shikeb Saddozai, identified in the opinion as a California inmate, filed a lawsuit without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state law for violating federal rights. The court had previously dismissed his complaint twice while allowing him to amend it to comply with rules governing the joinder of claims and parties. Saddozai then filed a second amended complaint.

Saddozai alleged that on or about April 30, 2018, while detained at the San Mateo County–Maguire Correctional Facility, Deputy Sheriff A. Arqueza repeatedly beat and battered him after he requested a jail grievance form. He alleged that Arqueza threw him to the ground, put his body weight and knees on Saddozai’s head, back, legs, and arms while handcuffing him, applied the handcuffs extremely tightly, placed him barefoot in a holding cell, threatened him with violence, and prevented him from obtaining medical attention. Saddozai also alleged that Arqueza exposed him to unsanitary conditions and later moved him to a housing unit and cell with worse conditions.

Saddozai further alleged that Arqueza confiscated and reviewed his property, including legal documents, outside his presence to prevent him from filing a complaint and assisting in ongoing criminal proceedings. He also alleged that Arqueza brought false disciplinary charges against him without a hearing or justification, resulting in the loss of various privileges. Saddozai sought declaratory relief, an order requiring action, and damages.

Screening and claims

Because Saddozai was a prisoner suing an officer, the court was required to screen the complaint under 28 U.S.C. § 1915A. Screening requires dismissal of claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant, while requiring the court to read a self-represented litigant’s allegations liberally.

The court found that the allegations were sufficient to proceed on claims for excessive force under the Eighth Amendment, deliberate indifference to serious medical needs, and unsanitary prison conditions. The court also found a due process claim based on the allegedly false and unjustified disciplinary action. The opinion states that the disciplinary-action allegations supported a due process claim, but not a First or Eighth Amendment claim.

The court dismissed the First Amendment retaliation claims. It explained that Saddozai had not alleged that Arqueza’s actions chilled the exercise of his First Amendment rights or that the actions failed to advance a legitimate correctional goal. The court denied Saddozai another opportunity to correct that deficiency after he had already received two opportunities to amend.

The court also dismissed the Sixth Amendment claim concerning the confiscation and review of Saddozai’s property. It found no basis for that claim because the lawsuit did not involve an ongoing criminal prosecution against Saddozai.

Order

The court ordered that Saddozai’s First and Sixth Amendment claims were dismissed for failure to state a claim. The claims allowed to proceed were the Eighth Amendment claims for excessive force, deliberate indifference to serious medical needs, and unsanitary conditions, along with the due process claim concerning the allegedly false and unjustified disciplinary action.

The clerk was directed to send Arqueza the lawsuit, service-waiver materials, the second amended complaint, its attachments, and the order. The court directed the defense to file a summary-judgment motion or another dispositive motion concerning the claims found cognizable within 91 days after the order was filed. The court also set deadlines for Saddozai’s opposition and the defense reply, permitted discovery under the Federal Rules of Civil Procedure, and warned that failure to prosecute or comply with court orders could result in dismissal. Judge Beth Labson Freeman signed the order.