Pringle v. Jose

Background

Mathew Malik Pringle brought a civil-rights action under 42 U.S.C. § 1983. He alleged that he tripped over a doorstop that was improperly placed in a walkway, injuring his ankle, knee, and back. He further alleged that officials placed him in a medical cell without raised furniture or furniture that would help an injured person rise from the floor, prescribed only Tylenol for his pain, and denied him a lower-bunk medical order.

Screening Standard

Because the action involved a prisoner seeking relief from a governmental entity or its officials, the court conducted the preliminary screening required by 28 U.S.C. § 1915A. At that stage, the court had to identify claims that were legally sufficient and dismiss claims that were frivolous, malicious, failed to state a claim, or sought money from an immune defendant. To state a claim under § 1983, a plaintiff must allege both a violation of a federal right and action by a person acting under state law.

Claims and Defendants

The court said Pringle’s allegations were sufficient to implicate the Eighth Amendment. It nevertheless found that the complaint could not proceed as filed because Pringle had not identified a proper defendant and had not supplied all necessary facts.

The court held that Pringle had not stated an Eighth Amendment claim based on the trip and fall because he did not allege that a prison official placed the doorstop with deliberate indifference to inmate safety. “Deliberate indifference” requires the official to have the culpable mental state required for an Eighth Amendment violation. The court instructed that any amended complaint would need facts supporting that mental-state allegation.

The court found that Pringle’s allegations about inadequate pain medication, the medical cell, and the denial of a lower bunk were sufficient at the pleading stage to state an Eighth Amendment claim. But Pringle had to identify the officials responsible for those alleged deprivations.

Pringle named Dina Jose, identified as Director of the Napa County Department of Corrections, and Lt. Fernandez, identified as an administrator in that department. The court said Pringle did not allege that either person personally deprived him of his rights, directed the alleged deprivation, or knew it occurred. Section 1983 does not impose liability merely because someone supervises other employees. The court therefore dismissed the claims against Director Jose and Lt. Fernandez with leave to amend. Pringle could amend by alleging their personal involvement or by naming officials who were personally involved.

As to the Napa County Department of Corrections, the court explained that Pringle would need to allege that a department policy or custom caused the constitutional violation and that the policy amounted to deliberate indifference and was the moving force behind the violation. The court also ruled that any claim against the “owners” of the department was dismissed without leave to amend because the department is a public entity and has no owners.

Disposition

The court dismissed the complaint with leave to file an amended complaint by July 7, 2021. The amended complaint had to use the required caption and case number, be filed on the court’s form, include every claim and defendant Pringle wished to pursue, and not incorporate the earlier complaint by reference. The court warned that failure to comply would result in dismissal under Federal Rule of Civil Procedure 41(b) for failure to prosecute. This was a screening and pleading ruling, not a final decision on the underlying Eighth Amendment allegations.