Uniloc 2017 LLC v. Google LLC

Background

Michael Handy, who was incarcerated at Pelican Bay State Prison and represented himself, brought a civil-rights action under 42 U.S.C. § 1983 against correctional officers J. Taylor, A. Harris, J. Rice, J. Rhodes, and Lieutenant J. Frisk. He sought monetary damages based on an alleged excessive-force incident on April 18, 2019. He also alleged that officials issued fabricated or falsified disciplinary reports and that Frisk improperly decided the disciplinary charges.

The court had previously allowed Handy to proceed without prepaying the filing fee and had denied his request for appointed counsel. Handy also sought to add claims described as retaliation and deliberate indifference.

Court’s analysis

The court conducted the required preliminary screening of a prisoner’s complaint. To state a claim under Section 1983, Handy had to allege both a violation of a federal right and conduct by a person acting under state law. He also had to provide enough facts to show how each defendant personally caused the alleged violation. The court explained that merely attaching grievance and disciplinary documents was not enough; Handy had to state the necessary allegations in the complaint itself.

Regarding excessive force, Handy alleged only that he was “assaulted” by Taylor, Harris, Rice, and Rhodes. The court held that he needed to provide specific facts showing how each defendant used excessive force or had an opportunity to intervene but failed to do so. The court also reminded him that Section 1983 does not impose liability solely because a person supervises an employee.

Regarding the disciplinary proceedings, the court treated Handy’s allegations as a possible procedural due-process claim. Prison disciplinary proceedings must provide certain protections, including the required opportunity to present evidence and some reliable evidence supporting the decision. But a prisoner must also allege a sufficiently serious deprivation, such as an unusually severe hardship or action that inevitably affects the sentence’s duration. Handy did not allege that the punishments resulting from the guilty findings caused such a deprivation. The court allowed him an opportunity to amend this claim if he could provide sufficient facts and link Frisk’s conduct to the alleged deprivation.

Request to add claims

The court granted in part Handy’s request to add new claims. Any new claims had to arise from the same transaction or series of events as the existing claims and share common legal or factual questions with the defendants and claims already in the case. The court stated that unrelated claims against different defendants belonged in separate lawsuits. Any new claim also had to identify the defendant, the constitutional right allegedly violated, and the facts connecting that defendant to the violation.

Disposition

The court dismissed the complaint with leave to amend. Handy had 28 days from the order to file an amended complaint that completely replaced the original, included all claims he wished to pursue, linked each defendant to specific conduct, and stated whether he had exhausted or was prevented from exhausting available administrative remedies. The court warned that failing to file an amended complaint by the deadline would result in dismissal without prejudice. The court also granted in part the request to add new claims, subject to the joinder and pleading requirements, and directed the clerk to send Handy a blank civil-rights complaint form.