Martin v. Basnettt

Background

Floyd Aaron Martin, a state prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 concerning events at Pelican Bay State Prison from December 2016 through February 2017. His claims included retaliation, deliberate indifference, withholding mail, due-process violations, and unconstitutional conditions of confinement. He sought declaratory relief, monetary damages, and punitive damages.

The court had previously allowed claims to proceed against Sergeants Z. Basnett, K. Price, and S. Wright; Lieutenant Basso; Correctional Officers E. Burr, E. Contreras, R. Scruggs, D. Trone, Kauffman, and Chavez; and dismissed other claims. The defendants then moved for summary judgment.

Exhaustion of prison grievances

The Prison Litigation Reform Act requires a prisoner to properly complete available prison administrative remedies before bringing a federal action about prison conditions. The court found that Martin had properly exhausted only two groups of claims: claims against Basnett, Contreras, and Burr concerning the temporary confiscation of his property, and claims against Scruggs concerning the February 2017 withholding of mail and alleged retaliation based on that withholding.

The court found the following claims unexhausted because Martin’s grievances did not give prison officials adequate notice of them, or because the events occurred after the grievances were filed:

- The deliberate-indifference claim based on being held for several hours without food, water, or a restroom. - The retaliation claim alleging that property was confiscated because Martin refused to provide a cell-phone passcode. - Claims connected to disciplinary reports for possessing a cell phone or altered property. - Claims against Trone and Wright concerning their later investigation of the mail grievance. - Claims against Basso, Kauffman, and Chavez concerning retaliation or more than twenty cell searches.

The court granted summary judgment on these claims and ordered that they be dismissed without prejudice to refiling after Martin exhausts California’s prison administrative process.

Claims decided on the merits

For the properly exhausted conditions-of-confinement claim, Martin alleged that his clothing, bedding, and cleaning and hygiene supplies were unavailable for thirteen days after the property search. The court concluded that the evidence did not show a genuine dispute of material fact. Martin retained his mattress, received sheets and a blanket the next day, obtained some clothing from another inmate, received toilet paper, could shower with water, and was not shown to have suffered a sufficiently serious deprivation or to have been subjected to deliberate indifference. Summary judgment was therefore granted to Basnett, Burr, and Contreras on this claim.

For the mail claims against Scruggs, the court held that the evidence did not establish a First Amendment violation or a due-process violation. Scruggs forwarded one flyer advertising “stamps for cash” to the prison’s Investigative Services Unit because he believed it might violate prison rules concerning inmate business activity. Although Martin did not receive the prison’s specified mail-withholding form, the court found that he received oral and written notice that the mail had been forwarded and had the opportunity to appeal to another prison official. The court held that these procedures satisfied constitutional due process and granted judgment to Scruggs on the First and Fourteenth Amendment claims.

The court also granted judgment to Scruggs on Martin’s retaliation claim. It found no evidence that Scruggs knew about Martin’s earlier protected activity, opposed that activity, or gave a false or pretextual reason for forwarding the flyer. The court concluded that speculation about retaliatory motive was insufficient to defeat summary judgment.

Punitive damages and disposition

The court dismissed Martin’s punitive-damages claim, finding no indication that the defendants acted with the evil motive, intent, reckless indifference, or callous indifference required for punitive damages under § 1983.

The order states that the defendants’ motion for summary judgment was granted as to all claims. Specifically, the court granted summary judgment on the exhausted claims on the merits, dismissed the remaining unexhausted claims without prejudice to refiling after exhaustion, and dismissed the punitive-damages claim. The clerk was directed to terminate pending motions and close the file.