Guzman v. Jones

Background

Mayito Guzman, an inmate at California State Prison–Solano, filed this civil-rights action under 42 U.S.C. § 1983 concerning events at San Quentin State Prison, where he had previously been housed. The court reviewed his second amended complaint under the prisoner-screening statute, 28 U.S.C. § 1915A.

Guzman alleged that California Department of Corrections and Rehabilitation officials Allison and Tebrock implemented a Non-Designated Programming Facility policy that affected general-population inmates. He alleged that the policy created unsafe conditions by housing general-population inmates with Sensitive Needs Yard inmates, reduced his ability to earn good-time credits, discriminated against Northern California Hispanic inmates, retaliated against inmates involved in earlier hunger strikes, and formed part of a conspiracy. He also repeated allegations that Lieutenant Dorsey prepared a false classification form and that Officer Boerum relied on it to approve Guzman's transfer to a higher-level prison.

Screening analysis

Under 28 U.S.C. § 1915A, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. To state a claim under § 1983, a plaintiff must allege both a violation of a federal constitutional or statutory right and conduct by a person acting under state authority.

The court found that the second amended complaint again stated legally sufficient equal-protection and conspiracy claims against Dorsey and Boerum. The court did not reconsider claims and defendants that its earlier order had already dismissed with prejudice, including due-process claims and claims against Martin, Samara, Nguyen, Davis, Bloomfield, Hemenway, and Voong.

Rulings on Allison and Tebrock

The court held that the allegations against Allison and Tebrock did not state a legally sufficient equal-protection claim. General-population status was not a protected class, and the complaint did not allege facts showing that the policy intentionally targeted Guzman because of a protected class. The court also concluded that the policy treated him the same as other similarly situated general-population inmates, defeating a “class of one” equal-protection theory. Because the complaint did not state an underlying constitutional claim against Allison and Tebrock, it also did not state a conspiracy claim against them. The court dismissed both claims with prejudice and dismissed Allison and Tebrock from the action with prejudice.

Unnamed defendant

The court again dismissed the unnamed classification staff representative, referred to as John Doe CSR, without prejudice. If Guzman learns the person's identity through discovery, he may ask to file a third amended complaint naming that person.

Disposition and next steps

Judge Haywood S. Gilliam, Jr. granted the defendants' request to screen the second amended complaint and reset the deadline for a dispositive motion. The court ordered defendants to file a summary-judgment motion or another dispositive motion no later than 91 days after the order was filed, followed by the opposition and reply deadlines stated in the order. The claims against Dorsey and Boerum remained in the action for further proceedings.