Moss v. Uribe

Background

Christopher Moss, representing himself, sued Salinas Valley State Prison correctional officers Tereasa Uribe and Amanda Garcia and Chief Physician and Surgeon D. Bright under 42 U.S.C. § 1983. He sought money damages and injunctive relief based on a December 1, 2017 incident. Moss alleged that Uribe used excessive force by handcuffing him behind his back despite a medical accommodation, that Bright failed to provide adequate treatment for injuries to his wrists, and that Garcia interfered with his prison grievance. He also asserted a state-law negligence claim.

The defendants moved for summary judgment, which is a decision without a trial when the evidence shows that no genuine dispute over an important fact requires a trial. Moss did not file an opposition. The court nevertheless considered the motion on the evidence, including Moss’s verified complaint, which could be treated as evidence for summary-judgment purposes.

Rulings

The court dismissed Moss’s claims for injunctive relief as moot because he was no longer incarcerated at Salinas Valley State Prison and therefore could not obtain effective relief concerning his prior confinement there.

The court granted defendants’ motion for summary judgment in part on Moss’s First Amendment claim against Garcia. The court held that prisoners have a right to file grievances but not a right to a response or a particular action on those grievances. It found that Garcia, a correctional floor officer, was not responsible for processing grievances and that Moss was able to file other grievances concerning the incident. Even assuming Garcia received and failed to file one grievance, the court held that this alone was not actionable under 42 U.S.C. § 1983.

The court also granted summary judgment on Moss’s Eighth Amendment deliberate-indifference claim against Bright. The court found that Moss had not properly exhausted the available prison grievance process as to Bright’s treatment of the alleged handcuffing injuries. The court dismissed that claim without prejudice to refiling after exhaustion of California’s prison administrative process.

The court granted summary judgment on Moss’s Eighth Amendment excessive-force claim against Uribe. Viewing the facts in the light most favorable to Moss, the court concluded that the evidence did not show that Uribe handcuffed him maliciously or sadistically to cause harm. The court relied on evidence that the cell search took about ten to fifteen minutes, that Moss’s medical accommodation did not completely prohibit handcuffing, and that the record did not show significant injury caused by the handcuffing. The court separately held that Uribe was entitled to qualified immunity, which can protect an officer from damages when the officer’s conduct did not violate a clearly established constitutional right.

The court denied defendants’ motion for summary judgment in part as to the remaining state-law negligence claim. Because it had granted summary judgment on the federal claims, the court declined to continue exercising supplemental jurisdiction, meaning its authority to hear a related state-law claim. It dismissed the negligence claim without prejudice to filing it in state court.

Disposition

Judge Donna M. Ryu dismissed the injunctive-relief claims as moot; granted defendants’ motion for summary judgment in part on the claims against Garcia, Bright, and Uribe; denied the motion for summary judgment in part as to the negligence claim; dismissed the negligence claim without prejudice to filing in state court; terminated pending motions; and closed the file.