Wilson v. Warden of San Quentin State Prison

Background

Van Otis Wilson, a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against the Warden of San Quentin State Prison and the Secretary of the California Department of Corrections and Rehabilitation. Wilson alleged that the department was not adequately prepared for a possible COVID-19 outbreak after more than 120 inmates were transferred from Chino State Prison, which had experienced an outbreak.

Wilson alleged that San Quentin then experienced an outbreak that infected approximately 75 percent of the inmate population and dozens of staff members. He said that, after testing negative, he was kept in an extremely small cell with an inmate who had tested positive. About three weeks later, Wilson tested positive. He alleged serious symptoms, including inflammation around his heart and other internal physical abnormalities, and said he received daily medical monitoring and medication. He sought monetary damages and placement in a residential facility supervised by the California Department of Corrections and Rehabilitation.

Screening and Claims

Because Wilson was a prisoner seeking relief from government officials, the court conducted the preliminary review required by 28 U.S.C. § 1915A. At this stage, the court had to identify claims that were legally sufficient and dismiss claims that were frivolous, malicious, inadequately pleaded, or sought money from an immune defendant. The court also stated that pleadings filed without a lawyer must be read liberally.

The court concluded that the complaint stated a cognizable Eighth Amendment claim for deliberate indifference to Wilson’s health and safety. The claim was based on his continued housing at San Quentin with an inmate who had tested positive for COVID-19, allegedly resulting in Wilson’s infection.

Rulings and Case Status

The court dismissed Wilson’s request for placement in a particular residential facility because a prisoner has no right to transfer to a particular institution or facility. It also dismissed the Secretary of the California Department of Corrections and Rehabilitation from the action for failure to state a claim, explaining that Wilson made no specific allegations showing how the Secretary actually or proximately caused his injuries.

The action proceeds solely on the Eighth Amendment claim against the San Quentin warden. The clerk was directed to terminate the other defendants and serve Warden Ron Broomfield. The court ordered defendants to file a motion for summary judgment or another dispositive motion concerning the cognizable claim within 91 days after the order was filed. It also set deadlines for Wilson’s opposition and defendants’ reply, and stated that discovery could proceed under the Federal Rules of Civil Procedure. Wilson’s request to proceed without paying the filing fee was to be addressed in a separate order.