Steward v. County of Santa Clara

Background

Defendants’ motion for summary judgment was scheduled for a March 6, 2020 hearing. The motion argued, among other things, that Steward’s federal and state claims against Graham should be dismissed because he failed to satisfy applicable exhaustion or claims-presentation requirements. The opinion states that defendants submitted evidence that Steward did not file a prison grievance concerning the alleged “rough ride” involving Graham, and that Steward’s opposition did not specifically address the federal administrative-exhaustion argument.

Legal requirements discussed

The court explained that the Prison Litigation Reform Act generally bars a prisoner from bringing an action about prison conditions under 42 U.S.C. § 1983 or another federal law until available administrative remedies have been exhausted. The court also explained that this federal exhaustion requirement does not apply to state-law claims.

The court’s research identified a separate California requirement. The California Government Claims Act generally requires a person seeking damages for injury to a person or personal property from a California governmental entity or employee to present the claim to the California Victim Compensation and Government Claims Board before filing suit. The statute also contains deadlines for presenting the claim and filing an action after written rejection. The court noted that timely presentation is a condition that must be met to maintain a covered action.

Order

The court did not decide the summary-judgment motion in this order. Instead, Judge Susan Illston directed the parties to submit supplemental briefs and supporting evidence addressing whether Steward complied with the California Government Claims Act concerning his state-law claims against Graham. The submissions were due by 3 p.m. on Friday, February 28, 2020.