Jones v. Runge

Background

Ronald Anthony Jones, a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against officers at San Quentin State Prison. He alleged that on October 11, 2018, he was placed in administrative segregation for allegedly possessing a cell phone and that Kyle Runge and Glen Amor, identified as the prison’s property officers, took his personal property. After Jones was found guilty of the rules violation on November 7, 2018, he was directed to send the property home. Jones alleged that Runge and Amor refused to return it. He sought declaratory relief, an injunction, and damages.

Screening standard

The court screened the complaint under 28 U.S.C. § 1915A, which requires review of a prisoner’s complaint against government entities or officials. The court had to dismiss claims that failed to state a claim for relief or sought money from an immune defendant. To state a claim under § 1983, Jones had to allege both a violation of a federal constitutional or statutory right and action by someone acting under state authority.

Claims and analysis

Due process. Jones described the withholding of his property as random and unauthorized. The court held that an intentional or negligent loss of property does not support a federal due-process claim under § 1983 when the state provides an adequate way to seek compensation after the loss. The court found that California provides such a remedy and dismissed the due-process claim for failure to state a claim. The order stated that this claim was dismissed with prejudice and that Jones could pursue it in state court.

Eighth Amendment. The court dismissed Jones’s claim that the property loss violated the Eighth Amendment. That amendment requires prison officials to provide basic necessities such as food, clothing, shelter, sanitation, medical care, and personal safety. The listed property—such as books, photographs, writing supplies, an electric razor, a hot pot, and other items—did not constitute a basic necessity of life, so the alleged loss was not sufficiently serious to state an Eighth Amendment claim.

Equal protection. The court also dismissed Jones’s equal-protection claim. Jones alleged that other prisoners’ property grievances were granted while his was denied, but he did not allege that he belonged to a specific group or that he was treated differently because of membership in that group. The court further stated that an alleged violation of state prison regulations, without a violation of a federal right, does not establish a § 1983 claim.

Disposition

The court gave Jones one opportunity to file an amended complaint addressing the deficiencies in his Eighth Amendment and equal-protection claims. The remainder of the complaint was dismissed with leave to amend. The amended complaint had to be filed within 28 days, use the case caption and number specified by the court, and be labeled “AMENDED COMPLAINT.” The court explained that an amended complaint would replace the original complaint, and claims or defendants omitted from it would no longer be part of the action. The court also ordered that failure to respond on time would result in dismissal of the action without further notice. Judge Beth Labson Freeman signed the order.