Moffett v. Benefield

Background

Andrew L. Moffett, an inmate at Corcoran State Prison, filed this civil-rights action without a lawyer under 42 U.S.C. § 1983. The court had previously dismissed his original complaint while allowing him to amend it. This order reviewed the amended complaint under the Prison Litigation Reform Act's screening requirement, 28 U.S.C. § 1915A.

Moffett alleged that, after a March 17, 2016 riot in the C-Yard at Salinas Valley State Prison, Correctional Officer Benefield falsely accused him of assaulting another inmate and misidentified him in a disciplinary report. Moffett alleged that he was found guilty and received a 10-month term in the security housing unit. He also alleged that several African-American inmates were accused of assaulting the same inmate and were placed in administrative segregation, that Benefield had warned him not to use a typewriter to document matters against prison officials, and that prison staff did not allow him to use yard cameras to prove his innocence because the cameras allegedly were not working.

Screening analysis

Under § 1915A, the court was required to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a claim, or sought money from an immune defendant. The court stated that a § 1983 claim requires an alleged violation of a federal constitutional or statutory right by a person acting under state law.

The court explained that false accusations alone generally do not violate § 1983. But a false disciplinary charge may support a due-process claim if it resulted in a disciplinary decision that lacked the required procedural protections. Those protections include, among other things, notice, an opportunity to prepare and present evidence, a written decision, and a disciplinary decision supported by some reliable evidence.

Liberally construing the amended complaint, the court found a cognizable due-process claim against Benefield. Moffett's allegation that the assault charge was false could be understood as alleging that the disciplinary decision was not supported by sufficient evidence. The court therefore ordered that this claim be served.

The court rejected Moffett's equal-protection claim. Although he alleged that he and other accused inmates were African-American and were placed in administrative segregation, he did not allege facts showing an intent or purpose to discriminate based on race. The court noted that the allegation that all inmates accused of assault were treated alike did not support an inference of purposeful discrimination.

The court also held that Moffett's claim concerning lost or destroyed property did not state a § 1983 claim. The court had previously explained that a random and unauthorized loss of property generally was not actionable under § 1983, although it might support a state-law claim if Moffett alleged timely compliance with California's Government Claims Act. Because he did not plead that compliance, the court dismissed the state-law property claim for failure to state a claim.

Disposition and case management

The order stated that the amended complaint stated a cognizable due-process claim against C/O Benefield and that all other claims and defendants were dismissed. The clerk was directed to issue a summons, and the United States Marshal was directed to serve Benefield without requiring advance payment of fees.

The court set a briefing schedule for a possible summary-judgment or other dispositive motion. It also informed Moffett about the evidentiary requirements for opposing summary judgment, allowed discovery under the Federal Rules of Civil Procedure, and directed him to serve copies of his court filings on defense counsel or, until counsel was designated, on Benefield. The order cautioned that failure to prosecute or comply with court orders could result in dismissal under Federal Rule of Civil Procedure 41(b).