France v. Bloomfield

Background

Michael R. France, a California prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against prison officials. The court had previously dismissed his complaint while allowing him to amend it. This order screened the amended complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner lawsuits against governmental entities or officials and dismiss claims that are frivolous, malicious, insufficiently pleaded, or barred by immunity.

Claims Allowed to Proceed

The court held that, when liberally construed, France’s claims that Ron Bloomfield, Arnold, King, and Lajun obstructed his access to the courts and were deliberately indifferent to his safety and medical needs were cognizable. The conclusion specifically describes the surviving claims as concerning access to the courts and France’s exposure to and treatment for COVID-19.

Claims Dismissed

The court ruled that France’s claims concerning improper discipline had to be brought in a habeas action because they involved the loss of time credits. The court also ruled that his claims alleging that defendants were not authorized to take his personal property did not state a due-process claim. It explained that California provides an adequate remedy after the alleged deprivation, which precludes federal due-process relief for this property claim. The order states that all other claims were dismissed.

Case Management and Disposition

The court ordered that Warden Ron Bloomfield, Captain Arnold, Sergeant King, and Lieutenant Lajun be served at San Quentin State Prison through the California Department of Corrections and Rehabilitation’s electronic-service program, with United States Marshals Service procedures for any defendant who did not waive service. The remaining defendants were directed to answer under the Federal Rules of Civil Procedure.

The court directed the remaining defendants to file a summary-judgment motion or another dispositive motion no later than 91 days after the order was filed, unless they informed the court that summary judgment could not resolve the case. France’s opposition would be due 28 days after service of such a motion, and any reply would be due 14 days later. The court allowed discovery under the Federal Rules of Civil Procedure and stated that no additional order was required before discovery could begin.

Judge William Alsup reminded France that he was responsible for prosecuting the case, keeping the court informed of address changes, and complying with court orders. The order states that failure to do so could lead to dismissal for failure to prosecute under Federal Rule of Civil Procedure 41(b).