Williams v. Koenig

Background

James David Williams, a state prisoner incarcerated at the Correctional Training Facility, filed a civil-rights action without a lawyer under 42 U.S.C. § 1983. He had been allowed to proceed without paying the filing fee. Williams named multiple officials and medical personnel at the facility as defendants and sought court orders and monetary damages.

Williams alleged that he experienced recurring back pain and that defendants denied disability accommodations, including a back brace and a ladder, handrail, or grab bar for access to an upper bunk. He also alleged that defendants denied requests for an magnetic resonance imaging scan and removed treatments or accommodations, including a low-bunk restriction. He characterized these allegations as violations of disability law and the Eighth Amendment’s protections against inadequate medical care and unsafe prison conditions.

Earlier Screening Order

The court previously screened the complaint under 28 U.S.C. § 1915A, a required initial review of a prisoner’s civil-rights complaint. The court found that Williams had not directly connected all of the named defendants to particular alleged actions. It also found that some defendants were mentioned only in a conclusory way and that claims against some supervisory officials appeared to rely improperly on their supervisory status alone.

The court further found that Williams’s deliberate-indifference allegations were conclusory. It instructed him to identify the specific acts of each defendant and to allege facts showing both a serious medical need and deliberate indifference by each defendant. The court also dismissed the upper-bunk-access claim with leave to amend, directing Williams to provide more information about the warden’s personal involvement and any officials who denied requests for a ladder, handrail, or grab bar.

The court gave Williams 28 days to file an amended complaint and warned that failing to do so would result in dismissal. Copies of the order were initially returned as undeliverable. After Williams updated his address, the Clerk re-sent the orders and gave him another 28 days, setting April 26, 2021, as the deadline.

Proceedings and Ruling

Williams did not file an amended complaint by the deadline. He also filed no further communications after submitting a notice of appeal on February 12, 2021. The Court of Appeals for the Ninth Circuit dismissed that appeal for lack of jurisdiction and later issued its mandate.

Applying Federal Rule of Civil Procedure 41(b), which permits dismissal when a plaintiff fails to prosecute an action or comply with court orders, the court found dismissal warranted. The court ordered that the complaint be dismissed without prejudice and that the Clerk close the file. Because the dismissal was based on Williams’s failure to file an amended complaint, the order did not decide the underlying disability or constitutional claims. Judge Yvonne Gonzalez Rogers signed the order.