Rael v. Pantoja

Background

Joseph Rael, an inmate at the Correctional Training Facility in Soledad, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. The court reviewed the complaint under the prisoner-screening statute, which requires screening claims against governmental entities and their officers or employees.

Rael alleged that on April 13, 2018, correctional officer J. Guerra initially refused to let him go to a prison job. Rael told Guerra that he would submit a staff complaint. After Guerra later allowed him to go to the job, Rael again said he would file a complaint. On April 17, 2018, correctional officer I. Perez-Pantoja asked Rael whether he had said he would “write him up.” Rael responded that the matter did not concern Perez-Pantoja, who allegedly suggested that it would be bad if the “homies” learned Rael was a snitch.

Rael further alleged that on April 21, 2018, Perez-Pantoja and Guerra entered his cell while he possessed a contraband cell phone and attacked him. He alleged that he was not threatening or resisting, but that the officers hit him with batons, sprayed him with pepper spray, slammed him to the ground, climbed on top of him, and applied handcuffs very tightly. He also alleged that Perez-Pantoja falsified a rule-violation report accusing him of resisting, disobeying orders, and assaulting the officers.

Claims and Analysis

The court explained that a claim under § 1983 requires an alleged violation of a federal constitutional or statutory right by a person acting under state law. Applying the required liberal reading to Rael’s self-represented complaint, the court found a cognizable Eighth Amendment excessive-force claim against Guerra and Perez-Pantoja based on the alleged April 21 use of force.

The court also found a cognizable First Amendment retaliation claim. Such a claim concerns adverse action taken against a prisoner because the prisoner engaged in protected conduct, such as complaining about prison officials. The court treated the alleged unnecessary force and false disciplinary report as adverse actions allegedly taken in response to Rael’s statement that he intended to file an inmate appeal.

Order

The court stated that the complaint presented cognizable § 1983 claims against I. Perez-Pantoja and J. Guerra. It directed the clerk to issue summonses and the United States Marshal to serve the defendants without requiring advance payment of fees. The court also established deadlines for the defendants’ summary-judgment or other dispositive motions, Rael’s opposition, and any reply.

The order was a screening and service order, not a final decision on liability. It did not grant or deny a summary-judgment motion and did not determine whether Rael would prevail at trial. It also provided procedural notices about summary judgment, service of filings, discovery, maintaining a current address, and prosecuting the case.