Hill v. Camacho

Background

Cymeyon V. Hill, a civil detainee in custody, filed a complaint without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state authority for violating federal rights. Hill alleged that events occurred at Salinas Valley State Prison in the fall of 2020. He named Dietician Mendosa, identified as the prison’s “food manager,” and sought injunctive relief and money damages, including punitive damages.

Hill alleged that he was served rancid food as part of a religious vegetarian diet. He said that he notified prison officials through the grievance process and told Mendosa that the food was making him sick, but Mendosa allegedly said she did not care and would continue serving it. Hill alleged vomiting, severe weight loss from lack of nutrition, stomach pain, headaches, and chest pains. He also alleged that an unnamed registered nurse denied him medical attention.

Screening and Claims

Because Hill sought relief from a government employee, the court screened the complaint under 28 U.S.C. § 1915A. Screening requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant.

The court dismissed Hill’s request for injunctive relief as moot. It reasoned that Hill had been transferred from Salinas Valley State Prison to California State Prison—Sacramento and that any possibility of returning to the earlier prison was too speculative to preserve a live request for injunctive relief.

The court held that Hill had stated a cognizable Eighth Amendment claim against Mendosa based on the alleged service of rancid food. The court explained that adequate food is a basic human need and that food can violate constitutional standards when it is so unsanitary that it becomes unwholesome and threatens prisoners’ health.

The court dismissed Hill’s First Amendment retaliation claim against Mendosa with leave to amend. Hill had generally alleged retaliation for filing grievances and court claims but had not provided enough facts showing protected activity, adverse action that could discourage an ordinary person from continuing that activity, and a causal connection between the activity and the adverse action. The court gave Hill one final opportunity to amend that claim and directed him to link Mendosa to the alleged retaliation.

The court dismissed the claim against the unnamed registered nurse without prejudice. It stated that, if Hill learned the nurse’s identity through discovery, he could seek permission to amend the complaint to name the nurse.

Order and Case Status

The court ordered that Mendosa be served with the complaint and the order. It referred the case to the Northern District of California’s Pro Se Prisoner Mediation Program for global settlement proceedings involving this case and other cases filed by Hill. After the operative complaint was served on the defendant or defendants with cognizable claims, further proceedings were stayed, and the clerk was directed to administratively close the case until further order. If mediation did not resolve the case, the court stated that it would issue a scheduling order.

Hill was allowed 28 days from the date of the order to file an amended complaint. The order stated that an amended complaint would replace the earlier complaint and must include all claims Hill wished to pursue, including the amended retaliation claim and the already cognizable Eighth Amendment claim.