Jamison v. Hatton

Background

Charles Edward Jamison, identified in the opinion as a California state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against officials and former officials at the Correctional Training Facility in Soledad and unknown officials at the California Department of Corrections and Rehabilitation. He sought declaratory relief and damages. The court said his request to proceed without paying the filing fee would be addressed in a separate order.

Jamison alleged that he contracted Valley Fever after construction of a medical facility at the Correctional Training Facility. He claimed that the facility and construction company did not take preventive measures to keep harmful fungal spores out of indoor air and did not provide him with a mask. He alleged that he began experiencing flu-like symptoms around the week of June 20, 2016, and was diagnosed with Valley Fever on December 19, 2016. He characterized the disease as lifelong and crippling and claimed that it amounted to cruel and unusual punishment under the Eighth Amendment.

Screening standard

Because a prisoner sued governmental officials, the court was required to screen the complaint. Screening requires dismissal of claims that are frivolous, malicious, fail to state a legally sufficient claim, or seek money from a defendant who is legally immune from that relief. The court also stated that a claim under Section 1983 requires allegations showing both a violation of a federal constitutional or statutory right and action by a person acting under state authority.

Court’s analysis

The court said an Eighth Amendment conditions-of-confinement claim has two requirements. First, the alleged deprivation must be objectively serious. Second, the official must have a sufficiently blameworthy state of mind, called deliberate indifference. For a health or safety claim, this means the official knew facts showing a substantial risk of serious harm, understood that risk, and disregarded it.

The court assumed, without deciding, that Jamison’s allegations satisfied the objective seriousness requirement. It held that the complaint did not satisfy the required state-of-mind requirement because it did not allege that any named defendant knew the construction would expose prisoners to airborne fungal spores that could cause Valley Fever and proceeded despite that knowledge. The court therefore found that the complaint lacked sufficient facts to state an Eighth Amendment claim.

The court also explained that Jamison had to connect each individual defendant to the alleged violation by describing that person’s actions or failure to act. Regarding the unknown defendants, the court stated that discovery could sometimes be used to identify defendants whose names were not known before filing. It advised that any unknown defendants named in an amended complaint would be dismissed, but that defendants identified through discovery could be named and served.

Disposition

The court ordered that the complaint be dismissed with leave to amend. Jamison was ordered to file an amended complaint on the court’s form within 28 days from the filing date of the order. The amended complaint had to use the case caption and case number specified by the court and answer all questions on the form. The court stated that the amended complaint would replace the original complaint, and that claims or defendants omitted from it would no longer be part of the action.

The court further ordered that failure to file an amended complaint within the allowed time would result in dismissal of the action without prejudice and without further notice. The Clerk was ordered to provide Jamison with two copies of the court’s complaint form.