Tamrat v. Sonoma County Main Adult Detention Facility Administration

Background

Herman Tamrat, a state prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. He had permission to proceed without paying the filing fee. The defendants included the Sonoma County Main Adult Detention Facility Administration, Sergeant Alcala, Deputy Mann, and others.

Screening standard

Because Tamrat was a prisoner suing a governmental entity or government personnel, the court was required to screen the complaint under 28 U.S.C. § 1915A. The court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, inadequately pleaded, or sought money from an immune defendant. The court also explained that a self-represented complaint is read liberally, but it still must provide enough factual detail to make a claim plausible.

To state a claim under § 1983, a plaintiff must allege both that a federal constitutional or legal right was violated and that the violation was committed by someone acting under state authority.

Excessive-force allegations

Tamrat alleged that, on October 25, 2019, he pushed his food tray through his cell-door slot to the ground as an act of protest and placed his hands through the slot. He alleged that Sergeant Alcala ordered him to remove his hands and keep them in his cell. After Tamrat refused, Alcala allegedly tried to pull his hands loose with Deputy Mann's assistance. Tamrat alleged that Alcala struck his wrist with a closed fist, hit his hand and knuckles with a flashlight, punched him in the face, and that Alcala and Mann twisted his arms and banged them against the tray slot. He alleged that he was injured.

For a pretrial detainee's excessive-force claim, the question is whether the force purposely or knowingly used was objectively unreasonable in the circumstances. The court concluded that Tamrat's allegations were sufficient to state a claim against Alcala and Mann.

Other allegations

Tamrat also made general allegations that he was denied medical and psychiatric care and subjected to retaliation, intimidation, and harassment. He said he did not receive enough assistance from classification officials and grievance officials. The court dismissed these claims with leave to amend because Tamrat did not provide specific allegations about them.

Disposition

The court dismissed the complaint with leave to amend. It required any amended complaint to be filed by April 23, 2021, using the caption and civil case number in the order and stating “AMENDED COMPLAINT” on the first page. The court explained that an amended complaint would replace the original complaint and must include all claims Tamrat wished to pursue. If he did not file an amended complaint, the case would proceed only on the excessive-force claim. The court also warned that failing to prosecute the case or follow court orders could result in dismissal for failure to prosecute.