Saddozai v. Bolanes

Background

Shikeb Saddozai, a state prisoner housed at Salinas Valley State Prison, brought this self-represented civil-rights action under 42 U.S.C. § 1983 against medical personnel at the Maguire Correctional Facility in San Mateo County. The case concerns an Eighth Amendment claim alleging deliberate indifference to serious medical needs. The defendants filed a motion for summary judgment on January 30, 2020. Summary judgment is a request for a ruling without a trial when the moving party argues that the record does not present a genuine factual dispute requiring trial.

Saddozai moved for additional time to oppose summary judgment, a preliminary injunction, and appointment of counsel. He cited limited access to the prison library and legal resources, alleged interference by a law librarian and with his mail, and described mental and physical health issues. He had already received four extensions totaling about seven months.

Extension of Time

The court granted one final 30-day extension to file an opposition to the defendants’ summary-judgment motion. The opposition was due no later than October 21, 2020, and the court stated that no further extensions would be granted. The defendants’ reply was due 14 days after Saddozai filed his opposition.

The court also stated that Saddozai’s claims concerning access to the courts, retaliation, and other alleged deprivations by staff at Salinas Valley State Prison were outside the scope of this action. The court directed that those claims be raised in a separate action because this case involved the Eighth Amendment medical-care claim against defendants who did not work at Salinas Valley State Prison.

Preliminary Injunction

Saddozai sought an order requiring prison officials to stop alleged retaliation, harassment, and obstruction of his access to the courts. A preliminary injunction is a temporary court order issued before final judgment. The court explained that such an order binds the parties and certain people acting with them, and that the court must have personal jurisdiction—the legal power to bind the relevant person or entity—to enforce the order.

Because this action involved medical personnel at the Maguire Correctional Facility, the court held that it had no jurisdiction over the Salinas Valley State Prison officials or law librarian whom Saddozai sought to restrain. The court therefore denied the motion for a preliminary injunction.

Appointment of Counsel

The court noted that it had previously denied three requests for appointed counsel and had found that appointment of a guardian ad litem was not warranted because there was no verifiable evidence of incompetence. Saddozai presented no new facts supporting reconsideration. The court denied the request for appointed counsel without prejudice for lack of exceptional circumstances. In the order’s concluding list, the court stated that Saddozai’s motions for a preliminary injunction and appointment of counsel were denied.

Disposition

The motion for an extension of time was granted, with the 30-day extension described as final. The motions for a preliminary injunction and appointment of counsel were denied. The order terminated Docket No. 56; it did not decide the pending summary-judgment motion.