Robertson v. San Francisco County Sheriffs Department

Background

William Anthony Robertson, an inmate at the San Francisco County Jail, filed a civil-rights complaint under 42 U.S.C. § 1983 without a lawyer. He alleged that he was denied due process in connection with his confinement, was denied an appeal, was treated indifferently by staff, was not given rights he associated with the Sixth Amendment, and was subjected to punishment by deputies through the authority of another deputy. The San Francisco County Sheriffs Department and other defendants were named.

Screening standard

Because Robertson sought relief from governmental defendants while incarcerated, the court screened the complaint under 28 U.S.C. § 1915A. That statute requires screening and permits dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also said that filings by people without lawyers must be read liberally.

To state a claim under Section 1983, Robertson had to allege both a violation of a right secured by federal law or the Constitution and conduct by a person acting under state law.

Reasons for dismissal

The court held that the complaint failed to state a claim because Robertson’s due-process and unspecified Sixth Amendment allegations were not supported by facts. The court directed him to provide a short and plain statement of the facts supporting each claim rather than labels, conclusions, or a formulaic statement of legal elements.

The court also explained that there is no federal constitutional right to a jail or prison grievance system. Officials generally are not liable for a due-process violation merely because they mishandled, denied, or granted an inmate appeal. The court instructed Robertson to omit any claim based only on the handling of his inmate appeals.

If Robertson intended to challenge the lawfulness of his current custody, the court said he had to use a petition for a writ of habeas corpus rather than a Section 1983 action. The court further instructed him to identify each individual defendant and explain what that person did or failed to do. It explained that a supervisor’s liability requires personal involvement or a sufficient causal connection to the alleged constitutional violation.

Robertson also named the San Francisco County Sheriffs Department but alleged no facts against it. The court explained that a local government is not automatically liable for an employee’s conduct. To plead a municipal-liability claim, Robertson had to identify a specific policy, custom, or practice that plausibly caused the constitutional violation and amounted to deliberate indifference to his constitutional right.

Finally, the court directed Robertson to state whether he was a pretrial detainee or had already been convicted when the relevant events occurred, because different constitutional standards may apply.

Disposition

Judge Susan Illston dismissed the complaint with leave to amend. Robertson was ordered to file an amended complaint by March 27, 2020, using the case caption and civil case number from the order and placing the words “AMENDED COMPLAINT” on the first page. The amended complaint had to provide a complete statement of his claims. The court warned that failure to file it would result in dismissal of the action.