Murray v. Hoffman

Background

Rickey Paul Murray, who was in custody at the California Medical Facility, filed a civil-rights complaint under 42 U.S.C. § 1983 against officials from the Correctional Training Facility. He alleged that he was temporarily transferred there in March 2019 and placed in a status known as “confined to quarters.” According to the amended complaint, during a 15-day period J. Ibarra, Y. Martinez, and M. Zavala denied him basic necessities, including clean clothing, linens, blankets, soap, shampoo, toothpaste, a toothbrush, razors, law-library access, phone time, and writing materials. Murray also alleged that the conditions worsened his eczema and depression and caused other physical and mental suffering. He sought money damages.

Murray initially named Chief Deputy Warden K. Hoffman and Correctional Counselor II G. Guinn as defendants as well. The court had dismissed the original complaint with leave to amend because it did not adequately explain the duration of the alleged deprivation or the defendants’ awareness of a serious risk to Murray’s health or safety. Murray’s amended complaint named only Ibarra, Martinez, and Zavala.

Screening and claim allowed to proceed

Because Murray was a prisoner seeking relief from government officials, the court screened the amended complaint under 28 U.S.C. § 1915A. The court explained that an Eighth Amendment conditions-of-confinement claim requires allegations showing both an objectively serious deprivation and that the official had a sufficiently culpable state of mind.

The court concluded that the amended complaint stated a cognizable Eighth Amendment claim against Ibarra, Martinez, and Zavala. The court relied on Murray’s allegations about the nature and duration of the deprivation, his requests for basic necessities, his medical and mental-health conditions, and the officers’ alleged continued refusal to provide the necessities or refer him to a physician. A “cognizable” claim is one sufficient to continue past the initial screening stage; the order did not determine that the officers actually violated the Eighth Amendment.

All claims against Hoffman and Guinn were DISMISSED without prejudice because Murray’s amended complaint did not name them. The clerk was directed to send the required lawsuit and service materials to Ibarra, Martinez, and Zavala. The order also established procedures for their answer, later dispositive motions, discovery, and further case management.

Motion concerning counsel

Murray moved for an extension of time to seek and retain counsel. The court denied that request because there was no deadline for him to retain counsel, and he did not describe his efforts to obtain a lawyer, identify a particular lawyer, or explain how an extension would help him retain counsel.

To the extent the motion requested appointment of counsel, the court denied that request without prejudice. The court found that exceptional circumstances were not present because the likelihood of success could not yet be determined and the legal issues were not complex. “Without prejudice” means the order did not bar a later request.

Disposition

The court ordered service on Ibarra, Martinez, and Zavala, allowed the Eighth Amendment claim against them to proceed, DISMISSED without prejudice the claims against Hoffman and Guinn, DENIED Murray’s motion for an extension of time to retain counsel, and DENIED without prejudice any request for appointed counsel. The order terminated Docket No. 10.