King v. Davis

Background

Leonard King, an inmate at San Quentin State Prison who was representing himself, filed a civil-rights complaint under 42 U.S.C. § 1983. The court reviewed the complaint under the prisoner-screening statute, 28 U.S.C. § 1915A.

King alleged that Bloomfield, Franco, Velasco, Maxfield, Larkins, Young, and Voong engaged in a campaign of harassment and intentionally caused emotional distress. He alleged that these defendants conspired and fabricated evidence to secure a conviction that led to his placement in administrative segregation. He also alleged that Sandra Velasco made false statements and filed a false rule-violation report, that Lieutenant Sheldon found him guilty despite evidence supporting his position, and that Maxfield and Voong improperly canceled his inmate appeals.

King further alleged that he is diabetic and developed a medical problem while in administrative segregation. He attributed delayed medical attention and the need for an amputation to the low priority given to inmates in administrative segregation for medical care.

Court’s Analysis

The court explained that a complaint under Section 1983 must allege both a violation of a federal constitutional or statutory right and conduct by a person acting under state law. Although courts read self-represented pleadings liberally, a complaint must still include enough facts to make the claim plausible rather than relying on labels or conclusions.

Due process and disciplinary charges. False accusations alone do not violate the Constitution. A false disciplinary charge may support a claim only if it results in a serious enough deprivation of a protected liberty interest, such as an unusually harsh hardship compared with ordinary prison life or an effect on the length of the sentence. Even then, the claim generally requires a lack of the procedural protections required at the disciplinary hearing. King did not identify the length of his administrative-segregation term or whether he lost sentence credits. The court instructed him to provide those facts if he repeated these claims in an amended complaint, including the length of his sentence if he lost credits.

Conspiracy. The court held that King’s conspiracy allegations were merely conclusory. A civil conspiracy requires facts showing that the alleged participants had a shared unlawful plan or understanding. A conspiracy is not itself a constitutional violation under Section 1983, although it can help connect defendants to an underlying violation.

Medical care. A prisoner alleging unconstitutional medical care must show a serious medical need and deliberate indifference by a defendant. Deliberate indifference may include denying, delaying, or intentionally interfering with medical treatment. The court found that King had not stated a claim against any defendant because he did not identify what each defendant did or failed to do that caused the medical injury. Merely alleging that defendants caused his placement in administrative segregation, where the medical problem later developed, was not a sufficiently close causal connection. The court instructed King to allege facts beyond the filing of false charges or presiding over the disciplinary hearing.

Inmate appeals. The court explained that California prisoners have no federal constitutional right to a prison grievance or administrative-appeal system. Officials therefore are not liable under Section 1983 merely for denying, canceling, or improperly handling an inmate appeal. The court dismissed King’s due-process claims against Maxfield and Voong based on the canceled appeals without leave to amend.

Disposition

The court dismissed the complaint with leave to amend because it failed to state a claim against any particular defendant. King was ordered to file a complete amended complaint by April 10, 2020, using the case caption and number and labeling the first page AMENDED COMPLAINT. The court warned that failure to meet the deadline would result in dismissal of the action. Judge Susan Illston signed the order on March 5, 2020.