Wilson v. Valdez-Perner

Background

David W. Wilson, a California prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against prison officials and a state court judge. Section 1983 allows a person to seek relief for violations of federal rights by someone acting under state authority. The court screened the complaint under the federal statutes governing cases filed by people seeking to proceed without paying filing fees.

Claims the Court Rejected

Wilson alleged that defendants confiscated, lost, or destroyed his beard trimmer, television, and other personal property. The court held that these property claims were not legally cognizable because California provides an adequate state remedy for random and unauthorized property losses or destruction.

Wilson also alleged that defendants improperly handled or denied administrative grievances, transferred him to another prison, and filed a false disciplinary report. The court held that these allegations did not state constitutional claims: prisoners have no constitutional right to a prison grievance system, the state may transfer a prisoner among its institutions without violating the Constitution, and an allegedly mistaken disciplinary decision does not by itself establish a due-process violation.

Wilson further challenged rulings made by Judge M. Giorgi in one of his state-court cases. The court held that Judge Giorgi was absolutely immune from civil liability for damages based on acts performed in a judicial capacity.

Claim Allowed to Proceed

Wilson alleged that Valdez-Perner retaliated against him for filing administrative grievances against prison officials. Construing the complaint liberally, the court found that this allegation stated a legally cognizable First Amendment retaliation claim.

Ruling and Next Steps

Judge William Alsup ordered that Wilson’s claim against Valdez-Perner proceed and that Valdez-Perner be served. The order states that all other claims are dismissed. It does not state that the dismissals are with or without prejudice. The remaining defendants were ordered to answer, and the order set deadlines for a summary-judgment or other dispositive motion, Wilson’s opposition, and any reply. The court also permitted discovery under the Federal Rules of Civil Procedure.