Saddozai v. Bolanos

Background

Shikeb Saddozai, a state prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 against employees at the Maguire Correctional Facility in San Mateo County. The court had previously found that his amended complaint stated a legally cognizable Eighth Amendment claim against Deputy Sheriffs Lomu and Copeland for deliberate indifference to serious medical needs. Defendants filed a motion for summary judgment, which the court stated would be addressed in a separate order.

Motions to Reconsider Appointment of Counsel

Saddozai asked the court to reconsider its earlier denials of appointed counsel, citing limited legal materials, limited access to the law library and legal assistance, and the need for help with discovery. The court noted that he had continued to litigate the case, including by filing an opposition to summary judgment with supporting exhibits and seeking leave to amend his complaint. The court denied both motions for reconsideration.

Saddozai also generally sought an order requiring officials at Corcoran State Prison to stop violence, harassment, and retaliation. Because Corcoran State Prison was not a party to this case, the court ruled that it had no jurisdiction in this action to issue an injunction against that prison or its employees. The court stated that any claims against those employees would have to be brought in a separate civil-rights action.

Extension of Time

Saddozai requested an extension without specifying its purpose. The court treated the request as seeking additional time to oppose summary judgment. Although the opposition was due by January 28, 2020, Saddozai filed it on February 19, 2020. The court granted the extension and deemed the February 19 opposition timely filed.

Request to Add Defendants and Motion to Strike

Saddozai sought permission to file another amended complaint adding the Sheriff of San Mateo County and the City of Redwood City as defendants. He alleged generally that the existing defendants acted as the Sheriff’s employees and that the Sheriff and City acted through a policy or custom that caused constitutional violations.

The court denied leave to amend. It relied on Saddozai’s failure to explain why he had not previously alleged sufficient facts against Sheriff Bolanos or why he waited more than a year to seek to add a claim against the City. The court also found that allowing the amendment at that stage—after the summary-judgment motion had been fully briefed—would unduly prejudice the defendants.

The court further found the proposed amendment futile. Under § 1983, a person cannot be held liable solely because another person committed a constitutional violation. Likewise, a city or county cannot be held vicariously liable for its employees’ unconstitutional acts. A claim based on municipal policy or custom requires facts showing, among other things, a constitutional deprivation, a municipal policy, deliberate indifference to constitutional rights, and that the policy caused the violation. The court found Saddozai’s allegations about a conspiracy and policy conclusory and unsupported by factual allegations.

Saddozai filed a second amended complaint before receiving permission to do so. Because he had not obtained the required court authorization, the court granted defendants’ motion to strike that complaint.

Other Motions and Disposition

Defendants withdrew their administrative motion to file excerpts of Saddozai’s medical records under seal after his opposition indicated that he consented to the unredacted records being publicly accessible. The court terminated that motion as moot. It also directed the Clerk to terminate the amended motion concerning the hearing date because the case would proceed on the summary-judgment motion already filed.

Judge Beth Labson Freeman ordered: (1) the extension of time was granted and the February 19 opposition was deemed timely; (2) Saddozai’s motions to reconsider appointment of counsel were denied; (3) his motion for leave to file a second amended complaint was denied; (4) defendants’ motion to strike the second amended complaint was granted; and (5) the identified motions were terminated. The order did not decide the pending summary-judgment motion.