Hill v. Officer Macias

Background

Cymeyon V. Hill, a civil detainee held at California State Prison—Sacramento, filed a complaint without a lawyer under 42 U.S.C. § 1983. He alleged constitutional violations arising from an incident at Salinas Valley State Prison on March 22, 2021. The named defendants were Warden T. Lemon, Officer Macias, Psychologist Kimberly Seibel, and Counselor Jennifer Weaver. Hill also referred to five unnamed prison officials. He sought injunctive relief and money damages, including punitive damages.

Screening standard

Because Hill sought relief from governmental officials, the court screened the complaint under 28 U.S.C. § 1915A. The court was required to identify claims that could proceed and dismiss claims that were frivolous, malicious, inadequately pleaded, or sought damages from an immune defendant. The court also applied the requirement that a § 1983 claim allege a violation of a federal right by someone acting under state authority.

Claims and rulings

Injunctive relief. Hill’s transfer from Salinas Valley State Prison to California State Prison—Sacramento made his request for injunctive relief moot. The court therefore dismissed that claim.

Excessive force. Hill alleged that inmates attacked him and that Officer Macias repeatedly sprayed his face with pepper spray. He alleged injuries to his eye area, a fractured nose, severe eye damage, and treatment at an outside hospital and by an optometrist. The court held that, liberally construed, these allegations stated a cognizable Eighth Amendment excessive-force claim against Macias. This ruling allowed the claim to proceed; it did not resolve whether Hill ultimately would prevail.

Retaliation. Hill mentioned retaliation but provided no supporting facts and did not allege that he engaged in constitutionally protected activity. The court dismissed the First Amendment retaliation claim against Macias with leave to amend. Any amended claim had to identify the protected activity, Macias’s adverse action, the causal connection, and resulting harm.

Due process. To the extent Hill challenged the handling of a prison grievance or administrative appeal, the court held that the claim failed because there is no federal constitutional right to a functioning prison grievance or appeal system. The court dismissed that portion of the Fourteenth Amendment due-process claim for failure to state a claim, while allowing Hill to try to elaborate on the Fourteenth Amendment claim in an amended complaint if he could link defendants to a constitutional violation.

Supervisory liability. Hill sued Seibel, Weaver, and Lemon in their supervisory capacities, apparently based on Macias’s conduct. The court explained that supervisors are not automatically liable under § 1983 for another person’s actions. Because Hill did not allege facts showing the supervisors’ personal involvement, direction, knowledge with failure to act, or responsibility for an unconstitutional policy, the court dismissed the supervisory-liability claim with leave to amend.

Unnamed defendants and next steps

The court allowed Hill an opportunity through discovery to identify the five unnamed officials who allegedly failed to intervene. He was required to provide their names by the deadline for an amended complaint. If he did not do so, the Doe defendants would be dismissed without prejudice to later actions once their names became known.

Hill had 28 days to file an amended complaint using the court’s form. The amended complaint had to include all claims he wished to pursue, including the already-cognizable excessive-force claim, because an amended complaint replaces the earlier complaint. Failure to amend would leave the initial complaint operative and would result in dismissal of the specified claims as described in the order.

Mediation, stay, and service

The court referred the case, along with other cases Hill had filed, to Magistrate Judge Robert M. Illman for global settlement proceedings through the Northern District of California’s Pro Se Prisoner Mediation Program. After referral, further proceedings were stayed and the case was administratively closed until further order. If the case did not settle, the court stated that it would issue a scheduling order. The clerk was directed to begin service of the operative complaint and related documents on Officer Macias through the California Department of Corrections and Rehabilitation’s electronic-service process.