Pringle v. Jose

Background

Mathew Malik Pringle brought a complaint under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state law for violating rights secured by the Constitution or federal law. He named Dina Jose, identified as Director of the Napa County Department of Corrections; Lt. Fernandez, identified as an administrator in that department; the Napa County Department of Corrections; and the alleged “owners” of the department.

Pringle alleged that he was denied access to a telephone, religious services, the law library, a shower, cleaning supplies, and the jail yard for 14 days. He also alleged that he was prevented from contacting a private attorney or bail bondsman and was detained in a basement. The opinion said these allegations implicated the First, Sixth, Eighth, and Fourteenth Amendments.

Screening standard

The court conducted the preliminary screening required for a prisoner’s complaint seeking relief from a governmental entity or its officer or employee. At screening, the court must identify claims that are legally sufficient and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. To state a § 1983 claim, a plaintiff must allege both a violation of a federal right and action by a person acting under color of state law.

Defendants

The court dismissed the claims against Jose and Fernandez with leave to amend because Pringle did not allege facts showing that either person was personally involved in, or had integrally participated in, the alleged violations. The court stated that supervisors cannot be held liable under § 1983 solely because of their supervisory positions. An amended complaint would need to allege personal involvement by those defendants or name people who were personally involved.

The court also dismissed the claim against the Napa County Department of Corrections with leave to amend. A claim against a public entity based on a policy or custom requires facts showing that a policy existed, amounted to deliberate indifference to constitutional rights, and was the moving force behind the violation. Although Pringle referred to the jail’s “Covid-19 policy,” the court found it unclear whether he intended to base his claims on an official policy.

The court dismissed the claim against the alleged “owners” of the Napa County Department of Corrections without leave to amend because the department is a public entity and has no owners.

Alleged constitutional violations

For the First Amendment claims, the court requested more facts about the denial of telephone access, religious services, and law-library access. Regarding the telephone, Pringle needed to explain whether he could communicate with people outside the jail by other means and what explanation jail personnel gave for denying telephone access. Regarding religious services, he needed to explain whether the services were integral to his sincerely held religious beliefs, what explanation personnel gave, and whether the jail offered an alternative and why it was insufficient.

For the law-library claim, Pringle needed to explain why he wanted access, how the denial caused actual injury by hindering a legal claim, and what explanation personnel gave. The court also discussed that the law-library allegations might implicate the Sixth Amendment, depending on whether Pringle’s right to counsel had attached and whether the alleged restriction affected his defense against criminal charges.

The court held that the allegation that Pringle was denied showers for 14 days was sufficient to state an Eighth Amendment claim. It requested additional facts about why cleaning supplies were necessary, why Pringle wanted yard access and whether alternative exercise was available, and what harm resulted from detention in the basement, including the basement’s allegedly unsatisfactory conditions.

For the Fourteenth Amendment claim involving access to a bail bondsman, the court requested clarification about whether Pringle had telephone access immediately after arrest but lost it after booking, or whether he was never given access.

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, state “FIRST AMENDED COMPLAINT” on its first page, appear on the court’s form, include all claims and defendants Pringle wished to pursue, and not incorporate the prior 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. Judge William H. Orrick signed the order.