Barraillier v. Muniz

Background

Mario F. Barraillier alleged that, on March 8, 2018, at Salinas Valley State Prison, guards J. Alvarez and R. Ramirez used excessive force against him while he was in the medical unit. He alleged that guards A. Virrueta, K. Bock, J. Lopez, and E. Sanchez failed to intervene. The complaint asserted claims under 42 U.S.C. § 1983, a federal civil-rights statute, for violations of the Eighth Amendment, along with California claims for battery, negligence, intentional infliction of emotional distress, and violation of California Civil Code § 52.1, the Tom Bane Civil Rights Act.

Screening and Claims Allowed to Proceed

Because Barraillier was a prisoner seeking relief against governmental actors, the court screened the complaint under 28 U.S.C. § 1915A. At this stage, the court identified claims that were legally cognizable based on the allegations; it did not determine whether the alleged events were proved.

The court found that Barraillier stated an excessive-force claim against Alvarez and Ramirez. It also found that he stated Eighth Amendment failure-to-protect claims against Virrueta, Bock, Lopez, and Sanchez. The court further found that he stated the related California tort and Tom Bane Civil Rights Act claims against those same six defendants.

Claims and Defendants Dismissed

The court dismissed all claims against warden William Muniz because Barraillier alleged no facts directly linking Muniz to the guards’ conduct. The court explained that supervisory status alone does not establish liability under § 1983 and that a defendant must have participated in, directed, or been integral to the alleged constitutional violation, or known about it and failed to prevent it.

The court also dismissed all claims against nurse Giraccia, nurse M. Hunter, doctor H. Ibrahimi, doctor Preetranjan K. Sahota, and nurse Baldonado. Although medical staff have constitutional duties concerning medical care, the court concluded that the complaint did not establish an obligation for them to intervene in a physical attack by a guard.

The court dismissed Barraillier’s claims against Salinas Valley State Prison based on alleged municipal liability. It found that the allegations did not show a written or unwritten policy that tolerated, encouraged, supported, or ratified the employees’ alleged conduct. The court also dismissed all claims against Lieutenant D. Meredith because he was not named in the caption and no specific allegations were made against him.

Order

The court ordered the clerk to issue summonses and directed the United States Marshal to serve the complaint and order, without requiring advance payment of fees, on Alvarez, Ramirez, Virrueta, Bock, Lopez, and Sanchez. The clerk was also directed to send courtesy copies to the California Attorney General’s Office.

The court ordered the defendants to file a motion for summary judgment or another dispositive motion addressing the claims found cognizable by November 16, 2020. It stated that any exhaustion defense—the argument that Barraillier failed to complete available prison grievance procedures—should be raised in a summary-judgment motion. The order also set deadlines for Barraillier’s opposition and the defendants’ reply, allowed discovery under the federal rules, and required defendants to provide the required notice explaining how Barraillier could oppose summary judgment.

The court terminated William Muniz, Giraccia, M. Hunter, H. Ibrahimi, Preetranjan K. Sahota, and Baldonado as defendants, and stated that all claims against them were dismissed. It did not enter a final merits ruling on the claims proceeding against the six prison guards.