Williams v. Kernan

Background

Mario Williams and John Hunter, California prisoners, jointly filed a civil-rights action under 42 U.S.C. § 1983 against Scott Kernan, Ron Davis, Y. Samara, R. Broomfield, T. Boerum, and N. Walker. The operative complaint was the First Amended Complaint. Earlier proceedings resolved the due-process and equal-protection claims. The remaining claims were Williams’s claims under the First and Eighth Amendments.

From January 18 through March 12, 2018, prison officials placed all inmates in the dorms at San Quentin State Prison on a modified program while investigating violence, weapons, and planned assaults involving inmates in that area. The program lasted 53 days and prevented dorm inmates from traveling to the chapel in another facility. Chaplains from several denominations visited the dorms, but there was no Jehovah’s Witness chaplain. Williams could pray in his cell and request religious readings, literature, and other items from available chaplains. He said his religion prohibited him from attending services with people of another faith.

Williams also alleged that he lacked soap, toothpaste, toilet paper, and sufficient lotion; that the dorms were freezing; and that limited outdoor exercise worsened his back pain. He received antifungal cream after requesting medical help, more cream after running out, and ibuprofen for his back pain. He had outdoor exercise once during the modified program and could stretch and exercise indoors. Narcotics Anonymous and similar support programs did not continue during the program.

Summary judgment standard

Summary judgment is proper when the evidence shows no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. A material fact is one that could affect the result, and a genuine dispute exists when a reasonable jury could rule for the nonmoving party. The court must view disputed evidence in the light most favorable to the nonmoving party.

Administrative exhaustion

The Prison Litigation Reform Act requires prisoners to use available administrative remedies before filing suit. The defendants argued that Williams had not done so. The court rejected that argument. Williams filed or participated in at least six grievances concerning the modified program, including at least one pursued through the third and final level of review.

Officials first denied a grievance because the program was ongoing and under daily evaluation. When Williams and other inmates filed later grievances about the continuing conditions, officials denied them as duplicative. The court found that the later grievances addressed the continuation of the conditions over additional days and weeks. By refusing to address the complaints for those reasons, officials created a dead end and made the grievance process effectively unavailable to Williams. The defendants therefore were not entitled to summary judgment on exhaustion grounds.

First Amendment religious-practice claim

A prisoner must show that officials substantially burdened religious practice without a justification reasonably related to legitimate prison interests. The court found no triable issue supporting Williams’s claim. The evidence showed that inmates from the dorms had escaped and violently attacked sensitive-needs inmates in the other facility, that additional attacks were planned, and that some attacks occurred while inmates were traveling to places such as the chapel.

The court concluded that officials reasonably restricted movement to investigate the threat, identify dangerous inmates, and move them to another prison. Although security concerns may restrict attendance at religious services, inmates must have an alternative way to practice their faith. The court found that Williams could pray in his cell and obtain religious readings, literature, and other Jehovah’s Witness items through other chaplains, including the Catholic priest. It also found no evidence that the restriction was unreasonable, lasted longer than necessary, or denied Williams alternative means to observe his religion. The absence of a designated Jehovah’s Witness chaplain likewise did not establish a constitutional violation because prison officials were not required to provide clergy specifically for that faith.

Eighth Amendment conditions claim

For an Eighth Amendment conditions-of-confinement claim, the alleged deprivation must be sufficiently serious, and the official must act with deliberate indifference—meaning the official knows of and disregards an excessive risk to the prisoner’s health or safety.

The court held that restricting outdoor exercise to once during the 53-day program did not violate the Eighth Amendment. Inmate violence triggered the restriction, and there was no evidence that the restriction lasted longer than reasonably necessary to investigate and control the violence.

The court also found no evidence of deliberate indifference concerning the temperature, toiletries, lotion, or back pain. Officials responded to two heating complaints by having an engineer inspect, test, and restart the heating system. There was no evidence that defendants knew of inadequate temperatures on other occasions and failed to take reasonable steps. There was no evidence that the toiletries shortage was sufficiently severe or that defendants knew about it. Williams received medicinal cream that addressed his skin symptoms, could exercise indoors, and received ibuprofen. There was no evidence of a medical condition requiring outdoor exercise or that defendants knew of and disregarded such a condition. The court further held that lack of access to Narcotics Anonymous did not suggest a constitutional violation because there is no constitutional right to those rehabilitative programs.

Disposition

The court found no genuine dispute of material fact that could establish a violation of Williams’s First or Eighth Amendment rights. It granted the defendants’ motion for summary judgment. Because that conclusion resolved the remaining claims, the court did not reach the defendants’ additional arguments, including qualified immunity. The clerk was directed to enter judgment and close the file.