King v. Davis
- Susan Illston
- 3:19-cv-08201
- U.S. District Court · Northern District of California
- 3
In King v. Davis, Judge Illston dismissed Leonard King’s civil-rights case for failure to state a claim after his second amended complaint still lacked required facts.
Leonard King and the defendants named in his civil-rights action. The action was dismissed, and the court directed the clerk to close the file.
What happened
King v. Davis involved Leonard King’s claims that he was disciplined based on a false report and later received inadequate medical care while in segregated housing. He represented himself and sued under a federal civil-rights law.
The court said King did not allege that officials denied the procedural protections required for a prison disciplinary hearing. It also said he alleged a serious medical need but did not allege facts showing that any defendant knowingly disregarded that need.
Judge Susan Illston dismissed the action for failure to state a claim and directed the clerk to close the file. The court denied further permission to amend because it found that amendment would be futile.
The detailed version
- King v. Davis · No. 3:19-cv-08201
- Susan Illston
- Nov. 12, 2020
Background
Leonard King, an inmate at San Quentin State Prison, filed this civil-rights action without a lawyer under 42 U.S.C. § 1983. The court had previously dismissed his complaint and amended complaint but allowed him to amend. King then filed a second amended complaint, which the court reviewed under 28 U.S.C. § 1915A, a statute requiring courts to screen certain prisoner complaints.
Disciplinary-Due-Process Claim
King alleged that he was disciplined based on a false rule-violation report by Sandra Velasco accusing him of battery on a non-correctional officer. The court had previously explained that a prisoner claiming a due-process violation must identify the procedural protections he was denied. Those protections can include written notice, time to prepare, a written decision, the opportunity to present witnesses and documentary evidence when appropriate, assistance in certain circumstances, and a decision supported by some reliable evidence.
The court concluded that King’s second amended complaint did not allege that he was denied any of those protections. Although King alleged that other people gave statements supporting his account and disputing the complaining witness’s statements, the court explained that due process does not automatically require a hearing officer to accept the inmate’s defense. The court also reiterated that false disciplinary charges are not actionable under § 1983 when the required hearing protections were provided. The court therefore found that King failed to state a due-process claim and would not be given further leave to amend because he had not cured the identified deficiencies.
Medical-Care Claim
King also alleged that he received inadequate medical care and suffered a below-knee amputation after being placed in segregated housing because of the disciplinary proceeding. The court acknowledged that he had identified a serious medical need. But it found that he again failed to allege facts showing that any defendant acted with deliberate indifference—that is, knowingly disregarded a serious risk to his health. The court therefore found that the complaint did not state an Eighth Amendment claim for deliberate indifference to a serious medical need and would not allow another amendment.
Ruling
Judge Susan Illston dismissed the action for failure to state a claim upon which relief may be granted. The order directed the clerk to close the file. The opinion does not state that the dismissal was with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.