Saelor v. State of California

Background

Nai Feuy Saelor, a detainee at Napa State Hospital, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. The court had previously dismissed her second amended complaint while allowing her to amend. Saelor then filed a third amended complaint.

Claims and legal standards

The court screened the complaint under 28 U.S.C. § 1915A, which requires an initial review of complaints filed by prisoners seeking relief from governmental entities or their officers or employees. The court must dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant who is immune from that relief.

To state a claim under § 1983, a plaintiff must allege that a right protected by the Constitution or federal law was violated and that the violation was committed by someone acting under state authority. The court explained that verbal harassment and abuse generally do not establish a § 1983 claim.

The court also discussed protections for religious exercise under the Religious Land Use and Institutionalized Persons Act and the Free Exercise Clause. A viable religious-exercise claim requires allegations showing, among other things, that the religious belief is sincerely held and rooted in religion, and that the defendant burdened the religious practice without adequate justification.

Court’s analysis

Saelor alleged harassment and violations of her religious rights. The court found that the third amended complaint did not provide enough facts to make those claims plausible. It mentioned an incident involving a haircut but did not explain how the incident related to Saelor’s Buddhist beliefs. Saelor also stated that she was a Jehovah’s Witness in addition to embracing Buddhism and alleged that an unnamed defendant prevented her from bringing a camera to Jehovah’s Witness services. The court found that the complaint did not explain how that event was connected to her religious practices and did not make clear that it plausibly violated her rights.

Disposition

Judge Donato concluded that, after several opportunities to amend, Saelor had not stated a plausible claim and that further amendment would be futile. The complaint was dismissed without leave to amend for failure to state a claim. The opinion also states that the case was dismissed without prejudice. The Clerk was requested to close the case.