Moralez v. Davis
- Beth Freeman
- 5:20-cv-07860
- U.S. District Court · Northern District of California
- 3
In Moralez v. Davis, Judge Freeman dismissed Rudolph Moralez’s second amended civil-rights complaint without leave to amend for failing to state a claim.
Rudolph Moralez’s second amended civil-rights complaint was dismissed; Warden Ron Davis was the only named defendant in that complaint.
What happened
In Moralez v. Davis, Rudolph Moralez, a state prisoner representing himself, sued Warden Ron Davis and others under a federal civil-rights law. Earlier versions of his complaint were dismissed, but he was allowed to amend them.
Moralez initially claimed that unnamed prison officials failed to distribute face masks, causing him to become infected with the coronavirus. His second amended complaint instead made general allegations about inadequate medical care, missing medical records, and poor staff training and supervision, without explaining specific events or how Davis violated his rights.
The court dismissed the second amended complaint without leave to amend because it did not state a legally recognizable claim and Moralez had already been given two opportunities to correct the problems. Judge Beth Freeman issued the order.
The detailed version
- Moralez v. Davis · No. 5:20-cv-07860
- Beth Freeman
- Sept. 24, 2021
Background
Rudolph Moralez, a state prisoner housed at San Quentin State Prison, filed a civil-rights lawsuit without a lawyer under 42 U.S.C. § 1983 against Warden Ron Davis and others. Section 1983 allows a person to seek relief for a violation of federal rights by someone acting under state authority.
The original complaint sought relief under the Americans with Disabilities Act based on allegations that unnamed defendants failed to distribute face masks, resulting in Moralez becoming infected with the coronavirus. The court dismissed that complaint but allowed Moralez to amend it and instructed him to provide specific events, identify the people involved, explain how they violated his rights, and describe his resulting medical condition. The court also gave him the legal standards for an Eighth Amendment claim.
Moralez’s first amended complaint did not follow those instructions. It named only Warden Davis and generally alleged that Davis was responsible for inadequacies in the prison’s medical-care system. It did not mention the coronavirus or the alleged lack of masks. Moralez then filed a second amended complaint.
Claims and screening standard
Because Moralez was a prisoner seeking relief from government officials, the court was required to screen the complaint under 28 U.S.C. § 1915A. Screening requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court stated that pleadings filed without a lawyer must be read liberally.
In the second amended complaint, the only named defendant was Warden Davis. Moralez generally alleged that “Defendants” violated the Eighth Amendment through inadequate medical care, failure to keep medical records, and poor staff training and supervision. The complaint did not make specific allegations concerning the coronavirus, and it included exhibits without explaining their relevance.
Ruling
The court held that the second amended complaint failed to state any cognizable claims. It dismissed the second amended complaint without leave to amend, finding no good cause to provide another opportunity because Moralez had already been given two chances to correct the same deficiencies. Judge Beth Freeman issued the dismissal order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.