Vincent v. City and County of San Francisco

Background

Cameron Omari Vincent, a detainee proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. He alleged that jail conditions had negatively affected his health. Specifically, he said that a lack of sunlight over five years caused vitamin D deficiency, depression, low testosterone, and weak bones and teeth. He sought money damages and 30 to 60 minutes of sunlight each day.

Court’s analysis

The court screened the complaint under the federal prisoner-screening statute. That review requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court explained that a § 1983 claim requires an alleged violation of a federal constitutional or legal right by a person acting under state law.

Because Vincent was a pretrial detainee, the court explained that his conditions-of-confinement claim would be evaluated under the Fourteenth Amendment’s protection against punishment before conviction. A medical-care claim would require facts showing, among other things, that a defendant intentionally made a confinement-related decision, created a substantial risk of serious harm, failed to take reasonable available measures despite that risk, and caused injury. The court stated that Vincent’s complaint did not provide enough information to apply these standards because he identified no defendants.

Ruling

Judge Robert M. Illman dismissed the complaint with leave to amend. The court required Vincent to name specific defendants and describe how they violated his constitutional rights. He also had to explain whether and how he requested sunlight or outdoor time, how much outdoor time he received each week, whether he raised his medical concerns with medical officials and how they responded, and whether he was a party to the related litigation he mentioned. The court also directed him to state whether he was awaiting trial or had already been convicted.

The amended complaint had to be filed within 28 days of the order. It had to use the caption and case number in the order, identify itself as an amended complaint, and include all claims Vincent wished to pursue because an amended complaint replaces the original. The court warned that failure to amend on time would result in dismissal of the case. It also directed Vincent to keep the court informed of any address change and comply with court orders.