Reed v. California Department of Corrections
- Edward Chen
- 3:19-cv-07937
- U.S. District Court · Northern District of California
- 5
In Reed v. Unknown, Judge Demarchi found the amended complaint deficient but allowed one final amendment.
Charles Christopher Reed and the prison officials and correctional officers identified in his amended complaint.
What happened
Charles Christopher Reed, a state prisoner, sued over a finger injury he says occurred while working with a kitchen slicer. He alleged that prison supervisors and correctional officers knew about the work conditions and that he later could not obtain workers’ compensation.
The court screened his amended complaint and found that it did not provide enough detail to state a constitutional claim. The court said it was unclear whether the slicer was broken, whether officials knew it was broken, whether Reed was forced to use it, and how each supervisor or officer caused the injury.
Judge Virginia K. Demarchi allowed Reed to file one final amended complaint within 28 days. The court warned that failure to correct the defects could lead to a recommendation that the action be dismissed, but this order did not itself dismiss the action.
The detailed version
- Reed v. California Department of Corrections · No. 3:19-cv-07937
- Edward Chen
- Sept. 28, 2020
Background
Charles Christopher Reed, proceeding without a lawyer, filed a civil-rights action concerning an injury he says occurred while working in a prison kitchen. Reed alleged that Supervisor Jimenez directed him to cut cucumbers, that he used a slicer, and that he immediately cut off the side of his finger. He alleged that Supervisors Fagan, Conway, and Raymond and correctional officers Benefield, Watson, and Hidd were in agreement and knew that work was being performed. He also alleged that he was later told to file a workers’ compensation claim, but the state informed him that the California Department of Corrections was uninsured. He sought damages.
The court had previously screened Reed’s original complaint and dismissed it with leave to amend. Reed then filed an amended complaint.
Screening standard
Under 28 U.S.C. § 1915A, the court must screen a prisoner’s complaint seeking relief from a governmental entity or officer. The court must identify claims that are legally sufficient and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also must interpret a complaint filed without a lawyer liberally.
For a claim under 42 U.S.C. § 1983, a plaintiff must allege that a person acting under state authority violated a right secured by the Constitution or federal law. For prison work conditions, the Eighth Amendment applies only when a prisoner alleges that he was compelled to perform physical labor beyond his strength, dangerous to his life or health, or causing undue pain.
Court’s analysis
The court concluded that Reed’s allegations were too vague to establish an Eighth Amendment claim. The complaint did not clearly allege whether the slicer was broken or whether the supervisors knew it was broken. It also did not clearly allege that Reed was compelled to perform the work; his allegation that he chose the machine instead of a knife suggested that he may have had a choice.
The court further stated that Reed had not adequately alleged how the supervisors’ and correctional officers’ actions actually and proximately caused his injury. Supervisory liability cannot rest only on a supervisor’s position or conclusory allegations that the supervisor knew about unconstitutional conduct. The complaint needed allegations showing the required causal connection or culpable action or inaction.
Disposition
After screening, the court found that the amended complaint as pleaded failed to state a claim. The court granted Reed one final opportunity to file a second amended complaint, using the court form and including the information required by the form, including information about exhaustion of administrative remedies. The second amended complaint was due within 28 days of the order and would replace the original and first amended complaints.
The court stated that if Reed did not timely file a second amended complaint, or if the new complaint did not correct all identified defects, the court would issue an order reassigning the case to a district judge with a recommendation that the action be dismissed. The court clerk was directed to send Reed two copies of the court’s complaint form.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.