Gonzalez v. Ahern

Background

Fourteen current and former inmates of Santa Rita Jail filed a proposed class action under 42 U.S.C. § 1983, a federal civil-rights law. They sued Alameda County, the Alameda County Sheriff’s Office, Sheriff Gregory J. Ahern, detention officials and deputies, Wellpath Management, Inc., and Aramark Correctional Services LLC.

The complaint challenged 20 alleged jail conditions, including excessive lockdowns, inadequate recreation, unsanitary conditions, allegedly unsafe or inadequate food, inadequate medical care, group punishment, retaliation for complaints, limits on visits and communications, and charges for services. Plaintiffs asserted three § 1983 claims involving alleged failures to apply or alleged misuse of jail policies, medical care, and food.

The County Defendants, Wellpath, and Aramark separately moved to dismiss the amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. The County Defendants also moved to dismiss based on failure to exhaust administrative remedies under the Prison Litigation Reform Act, which generally requires prisoners to use available grievance procedures before bringing claims about prison conditions.

Exhaustion ruling

Judge Jacquelyn Scott Corley denied the County Defendants’ motion to dismiss based on failure to exhaust. Plaintiffs alleged that defendants intimidated or retaliated against inmates who tried to file grievances, refused to provide or accept grievance forms, and told inmates that certain issues were not subject to the grievance process. The court held that these allegations were sufficient at the pleading stage to support the possibility that administrative remedies were unavailable.

The court also explained that exhaustion is a non-jurisdictional affirmative defense. Because defendants sought dismissal under Rule 12(b)(6), they had not provided the evidence needed at that stage to show that available remedies existed and had not been exhausted.

Failure-to-state-a-claim rulings

The court granted defendants’ motions to dismiss for failure to state a claim. It dismissed the first claim with leave to amend because the claim did not identify which of the 20 conditions were at issue, which defendant was responsible for each condition, or which specific policies were unconstitutional, not followed, or absent. The court directed plaintiffs to plead each challenged condition in a separate claim and to identify the relevant defendants, their capacities, the supporting complaint allegations, and the specific constitutional provision involved.

To the extent the first claim relied on the Fifth Amendment, the court dismissed that claim without leave to amend. The court stated that the Fifth Amendment’s Due Process Clause and equal-protection component apply to federal-government actions, while plaintiffs did not allege that the actors in this case were federal actors.

The court dismissed the second claim, concerning alleged deliberate indifference to medical needs by the Sheriff and Wellpath, with leave to amend. The claim did not adequately identify the challenged policies, whose policies they were, whether they were written, whether written policies were not followed, or how the policies violated constitutional rights. The court also found that plaintiffs had not adequately explained how alleged violations of California regulations supported relief under § 1983.

The court likewise dismissed the third claim, concerning alleged deliberate indifference to the need for adequate food by the Sheriff and Aramark, with leave to amend. That claim did not sufficiently identify the challenged policies or explain how they violated constitutional rights. The court also found that the complaint did not adequately connect alleged violations of California regulations to a right to relief under § 1983.

Disposition

The court granted defendants’ motions to dismiss except as to the County Defendants’ exhaustion argument, which it denied. The dismissal was with leave to amend except for claims based on denial of plaintiffs’ Fifth Amendment rights. Any amended complaint was due within 30 days and had to separately state each claim.