Hill v. J. Beltran

Background

Cymeyon Hill, a civil detainee in custody at Salinas Valley State Prison, filed a pro se civil-rights complaint under 42 U.S.C. § 1983 against Property Officer E. Perez, Correctional Officer T. Beltran, Sergeant E. Black, and Sergeant O. Aragon. The court stated that Hill sought monetary and punitive damages. The complaint alleged that Hill was assaulted during a cell extraction on August 4, 2020, and that Perez, Beltran, and Black then destroyed personal property, including legal books, federal legal materials, stamps, headphones, and books from family. Hill stated, without additional detail, that the destruction was done “for retaliation.”

The court conducted the required preliminary screening under 28 U.S.C. § 1915A. Under that screening statute, the court must identify claims that can proceed and dismiss claims that are frivolous, fail to state a claim, or seek damages from an immune defendant. The court also explained that a § 1983 claim requires an alleged violation of a federal right by someone acting under state law, and that conclusory allegations and supervisory status alone are insufficient.

Claims and analysis

Property-destruction due-process claim. To the extent Hill alleged that officials improperly destroyed his property, the court held that the allegations described random and unauthorized property deprivations. Such deprivations do not support a § 1983 due-process claim when the state provides an adequate post-deprivation remedy. The court stated that California provides such a remedy and that these property claims must be pursued in state court if the federal court otherwise lacks jurisdiction over them.

Claim concerning O. Aragon’s handling of the grievance. The court understood Hill to have named Aragon because Aragon interviewed him about his grievance concerning the property destruction and the grievance was denied. The court dismissed this claim because the denial of a prison administrative appeal does not violate due process. The court stated that California inmates have no federal constitutional right to a prison grievance or appeal system that functions in a particular way.

Retaliation claim. The court dismissed Hill’s First Amendment retaliation claim with leave to amend. A prison-retaliation claim requires facts showing that a state actor took adverse action because of protected conduct, that the action chilled the inmate’s exercise of First Amendment rights, and that the action did not reasonably advance a legitimate correctional goal. The court found Hill’s statement that the property was destroyed “for retaliation” too conclusory. He did not identify the protected conduct or explain how each official knew about it.

Disposition

Judge Yvonne Gonzalez Rogers ordered that the complaint be dismissed with leave to amend. Hill was permitted to file an amended complaint that clearly states each claim, identifies the specific actions of each defendant, identifies the injury from each claim, explains exhaustion of administrative remedies or their unavailability, and includes only properly joined claims and defendants. The court also instructed Hill not to rely on conclusory allegations or supervisory liability without facts showing personal involvement.

Hill had 28 days from the date of the order to file the amended complaint. The amended complaint would completely replace the original complaint and had to include all claims Hill wished to pursue. The order stated that failure to file a timely amended complaint or correct the identified deficiencies would result in dismissal of the action without prejudice. The Clerk was directed to correct the spelling of O. Aragon’s last name and send Hill a blank civil-rights complaint form.