Ruffin v. San Francisco Sheriffs Department

Background

Shawn P Ruffin, an inmate at San Francisco County Jail, filed a self-represented action under 42 U.S.C. § 1983. The court screened his amended complaint under 28 U.S.C. § 1915A, which requires an initial review of a prisoner’s claims against governmental entities or employees. The court had previously dismissed his original complaint with leave to amend because it did not adequately identify federal-law or constitutional violations, did not provide sufficiently specific facts, appeared to improperly join unrelated claims, and did not identify defendants by name.

The amended complaint named the San Francisco Sheriffs Department in its official capacity and Lt. Daggs, Sgt. Leonardini, classification deputy Loufas, deputy Jacowitz, and senior deputy Mikovich. The opinion also discussed allegations involving deputies Truong and James, Captain Murphy, and Davis.

Allegations

Ruffin alleged that he was placed in confinement or administrative segregation beginning in May 2020 without a required hearing or adjudication. He alleged that Leonardini placed him in confinement, Jacowitz issued an incident report, Mikovich issued a loss-of-rights disposition, and Loufas continued holding him in confinement before his transfer to administrative segregation. The court found it unclear what Ruffin meant by “confinement” and “adjudication,” and it treated the allegations as challenging the lack of process before or after administrative segregation.

Ruffin separately alleged that on April 10, 2020, deputies placed him in Cell No. 5 for approximately two or three hours. He alleged that rust protruded from the bed, dark brown stains that were likely feces appeared on the walls and floors, the sink did not work, and the cell had recently been sprayed for COVID-19. He claimed that the cell placement violated the Eighth and Fourteenth Amendments.

Court’s Analysis

The court held that the amended complaint again relied on vague and conclusory statements that defendants acted illegally or with an improper motive. Such statements, without supporting facts, did not satisfy Federal Rule of Civil Procedure 8’s requirement for a short and plain statement showing entitlement to relief. The court also concluded that the two incidents appeared to be separate occurrences that did not share a common question of fact, potentially violating Rule 20’s limits on joining defendants and claims in one action.

As to administrative segregation, the court explained that violating state regulations alone does not create a constitutionally protected liberty interest. Due process requires an informal, nonadversarial hearing within a reasonable time, notice of the reasons for segregation, and an opportunity for the prisoner to present his views. The court said the amended complaint stated that Ruffin was informed of the reasons for segregation within four days, but did not allege that he was denied a hearing or an opportunity to present his views. It dismissed this due-process claim with leave to amend.

The court dismissed the due-process claim concerning Cell No. 5 with prejudice. It reasoned that the placement was too brief to implicate a protected liberty interest and that the alleged cell conditions belonged, if anywhere, under the Eighth Amendment rather than due process.

The court also dismissed both Eighth Amendment claims with prejudice. It ruled that the lack of an adjudication before administrative segregation did not constitute an objectively sufficiently serious deprivation under the Eighth Amendment. It further ruled that the two- to three-hour placement in Cell No. 5 was too brief to constitute an Eighth Amendment violation.

Disposition

The court dismissed with prejudice the due-process claim arising from the placement in Cell No. 5 and both Eighth Amendment claims. It dismissed with leave to amend the due-process claim arising from placement in administrative segregation. It also dismissed the amended complaint with leave to amend to address the pleading and claim-joinder deficiencies.

Ruffin was given 28 days from the date of the order to file a complete second amended complaint. The court stated that failure to do so as required would result in dismissal of the action without further notice.