Saddozai v. Bolanos

Background

Shikeb Saddozai, a state prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983. The court had previously found that an earlier complaint stated constitutional claims against Defendant Arqueza based on events at the Maguire Correctional Facility on April 30, 2018. Saddozai later amended his complaint to allege that he was a pretrial detainee and that the alleged violations occurred under the Fourteenth Amendment.

The third amended complaint also named the Sheriff of San Mateo County and the City of Redwood City. Saddozai alleged that Arqueza acted as an employee or agent of the Sheriff and that the Sheriff and City conspired or acted under a policy or custom that made them liable for Arqueza’s actions. He also generally invoked the Fourth, Fifth, Eighth, and Fourteenth Amendments and asserted state-law claims under supplemental jurisdiction.

Claims Against the Sheriff and City

The court screened the allegations against the newly named defendants. It held that Saddozai did not provide enough facts to state a claim against Sheriff Bolanos or the City based only on the conduct of subordinates or employees. Section 1983 does not impose liability solely because one person is responsible for another person’s actions, and a city or county cannot be held vicariously liable for employees’ unconstitutional conduct under respondeat superior.

For a municipal-liability claim based on governmental inaction or omission, the court explained that a plaintiff must show a constitutional right, a municipal policy, deliberate indifference to that right, and that the policy was the moving force behind the constitutional violation. The court found Saddozai’s allegations about a conspiracy and policy conclusory and unsupported by factual allegations.

The court denied leave to amend these claims. It relied in part on Saddozai’s prior amendments, his failure to explain why he had not previously alleged sufficient facts against the Sheriff, and his delay in seeking to add the City. The order therefore dismissed the claims against the Sheriff and the City for failure to state a claim and without leave to amend.

Claim Against Arqueza

The court stated that Arqueza had died while the case was pending. The court had directed Saddozai to try to identify Arqueza’s successor or representative and request service on that person. The deadline passed without Saddozai providing information about service.

Under Federal Rule of Civil Procedure 4(m), the court dismissed the claims against Arqueza without prejudice because Saddozai had not completed the required service-related steps. This ruling addressed service and did not decide the underlying constitutional claims against Arqueza.

Disposition

The court dismissed the claims against the Sheriff and the City for failure to state a claim and without leave to amend. It dismissed the claims against Arqueza without prejudice under Rule 4(m). Because no other claims remained, the court dismissed the entire case, terminated pending motions as moot, and closed the file.