Waddell v. Minton

Background

Nathaniel Waddell filed a pro se civil-rights action under 42 U.S.C. § 1983. The case was before the court for screening under 28 U.S.C. § 1915A, which requires a court to review a prisoner’s complaint against governmental entities or employees and dismiss claims that are frivolous, fail to state a claim, or seek relief from an immune defendant.

Waddell was housed at Santa Rita Jail and later sent to Napa State Hospital for restoration of competency to stand trial. He said his complaint concerned events at the jail. The complaint listed 33 defendants but alleged facts about particular people only in connection with some incidents.

Claims and analysis

The court assumed for purposes of screening that Waddell was a prisoner rather than a pretrial detainee when the events occurred, while allowing him to allege otherwise in an amended complaint. The court therefore analyzed his conditions-of-confinement claims under the Eighth Amendment. To state a claim under § 1983, Waddell had to allege both a violation of a federal right and action by a person acting under state law.

Mind-implantation technology. The court dismissed without leave to amend Waddell’s claim that jail officials used unseen devices to read his thoughts and implant thoughts and voices. Applying the screening statute’s authority to dismiss claims based on clearly baseless factual allegations, the court concluded that this claim was frivolous.

Verbal harassment. The court dismissed with leave to amend Waddell’s claims that guards told him to kill himself, threatened his and his family’s lives, and tried to provoke him into fighting. The court explained that verbal harassment ordinarily does not violate the Constitution. It noted, however, that deliberately inflicting psychological pain on a particularly vulnerable inmate might support a constitutional claim. Waddell was told to allege, if supported by facts, that he was suicidal, that the staff member knew of his vulnerability, and the name and date connected to the incident. The court also stated that emotional injury without physical injury was not actionable under the cited prisoner-litigation statute.

Uses of force. The court dismissed with leave to amend Waddell’s excessive-force claims. It explained that force used to respond to an inmate’s violent conduct is not automatically unconstitutional and instructed Waddell to allege facts showing that the force exceeded what was needed. It also required him to identify the particular defendants involved and provide dates when possible, including for the incidents involving deputy Micke and deputy J. Mayfield.

Safety-cell placement. The court determined that Waddell had not provided enough information to state an Eighth Amendment conditions-of-confinement claim based on placement in a safety cell covered with urine and feces. He had not alleged how long he remained there, what harm resulted, or what each particular defendant did or failed to do. The court dismissed this claim with leave to amend.

Lunch incident. The court dismissed Waddell’s allegation that deputy Calhoun emptied his lunch onto the floor, concluding that the alleged conduct did not rise to the level of an Eighth Amendment violation.

Disposition

The court dismissed the complaint with leave to amend. Waddell had to file a complete amended complaint using the case caption and number in the order and placing the words “AMENDED COMPLAINT” on its first page by August 3, 2020. The order warned that failure to file by that deadline would result in dismissal of the action. The order was signed by United States District Judge Susan Illston.