Belton v. Gutierrez

Background

Belton alleged that another prisoner attacked him on June 2, 2018, in the dayroom of his housing unit at Salinas Valley State Prison. He alleged injuries to his left hand and right hand and claimed that he later received constitutionally inadequate medical care. He also alleged that prison guard Roger Martinez denied him due process during a disciplinary hearing. The opinion states that Belton’s failure-to-protect, medical-care, and disciplinary-hearing claims were found legally sufficient to proceed, while claims against supervisory defendants were dismissed.

Belton filed two motions asking the court to compel discovery. He sought nine sets of documents, including personnel records and misconduct complaints, policies concerning pepper spray and dangerous prisoners, and records from the prison’s investigation of the June 2 incident. The defendants opposed the motions, stating that they had provided substantive responses to some requests and that other documents were protected by the official-information privilege. That privilege is a government’s asserted protection against disclosure of certain official records when disclosure could harm governmental or privacy interests.

Rulings on the Discovery Requests

The court denied the motion as to Request No. 1 because the defendants stated that no responsive documents existed. It denied Requests Nos. 2 and 3 because the requested policies were not relevant to Belton’s failure-to-protect and medical-care claims and the defendants had provided a substantive response.

For Request No. 4, the defendants identified a supplemental policy concerning forced cell extractions, including extractions involving prisoners with mental-health designations. The court stated that the policy’s relevance was not clear because the incident occurred in a dayroom and did not involve a cell extraction. The court ordered the defendants to submit the policy for an in camera review, meaning a private review by the judge, before deciding whether it was relevant or protected.

Requests Nos. 5 through 7 and 9 sought statements, reports, interviews, training-related materials, and other records concerning the prison’s investigation. The court ordered the defendants to submit the documents responsive to Requests Nos. 5 through 7 and 9 for in camera review. The court recognized the defendants’ stated safety concerns but said it could not determine whether disclosure, withholding, or redaction was appropriate without reviewing the documents. The court also invited the defendants to explain in a supplemental declaration whether Belton had received the core information in another form.

The court denied the motion as to Request No. 8, which sought certification and training records, because those records did not appear relevant and material to Belton’s case. It also stated that Sergeant Mislana’s requested investigative notes did not exist and need not be disclosed.

Other Orders and Disposition

The court stated that Belton’s motions to compel discovery, docketed as Nos. 44 and 47, were denied in part. Discovery was stayed pending further order. The defendants were directed to submit the specified policy and investigation documents for review, and no further discovery motions would be considered unless the court lifted the stay.

The court also denied as moot Belton’s motion to extend the time to respond to the defendants’ motion for summary judgment. The clerk was directed to terminate all pending motions. Judge William H. Orrick signed the order.