Chiprez v. Adame

Background

Froylan Medina Chiprez, a California prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983. He sued 24 defendants and sought injunctive relief, monetary damages, and punitive damages. The complaint described alleged events at Salinas Valley State Prison from January 2018 through May 2018 and at the California Substance Abuse and Treatment Facility from May 2018 through November 2019.

The court conducted its initial screening under 28 U.S.C. § 1915A. The court stated that, when liberally construed, the allegations concerning Salinas Valley State Prison described claims including deliberate indifference to safety, failure to remove Chiprez because of safety concerns, mail tampering, forgery of legal mail, failure to protect him from harassment and intimidation, interference with filing a federal habeas petition, and obstruction of mail to courts.

Rulings

The court found that the claims concerning the two prisons were improperly joined. The California Substance Abuse and Treatment Facility claims involved different defendants, prisons, time periods, and factual allegations from the Salinas Valley State Prison claims. The court therefore dismissed all California Substance Abuse and Treatment Facility defendants and claims from this action without prejudice to Chiprez filing separate actions in the Eastern District of California, which the court identified as the proper venue for claims based on events there.

The court also found that the complaint did not adequately show exhaustion of administrative remedies. Chiprez answered “No” when asked whether he had presented the facts in his complaint through the prison grievance procedure and marked the grievance-review levels “N/A.” The court dismissed the complaint with leave to amend so that he could allege and establish that he exhausted available administrative remedies for each claim against each Salinas Valley State Prison defendant before filing the action.

The court ruled that any amended complaint must comply with the federal joinder rule by including only claims arising from the same transaction, occurrence, or related series of events and presenting common legal or factual questions concerning the defendants. It also found that Chiprez had not clearly linked every Salinas Valley State Prison defendant to a specific alleged injury. The court directed him to identify each defendant’s specific action or failure to act and the resulting injury, and not to rely on conclusory allegations or supervisory liability based only on a defendant’s position.

Claims against defendants from the California Attorney General’s Office were dismissed with leave to amend. Chiprez was required to explain how those defendants were properly joined to the Salinas Valley State Prison claims, identify the specific defendants and alleged constitutional violations, and explain why any applicable immunity did not bar relief. The court dismissed the claims against Doe defendants without prejudice to Chiprez moving for leave to amend if he later learned their identities.

Required amendment and disposition

Judge Yvonne Rogers ordered Chiprez to file an amended complaint within 28 days. The amended complaint had to be short, clear, and complete; include each claim in a separate numbered paragraph; identify each defendant’s specific conduct and the resulting injury; explain exhaustion; satisfy the joinder requirements; avoid improper conclusory or supervisory-liability allegations; and omit Doe defendants. The amended complaint would replace the original complaint, and failure to file it or correct the identified deficiencies would result in dismissal of the action without prejudice. The order did not decide whether Chiprez’s underlying constitutional claims were ultimately valid.