Washington v. Magado

Background

Christopher N. Washington, a state prisoner confined at Mule Creek State Prison, filed this lawsuit without a lawyer under 42 U.S.C. § 1983. He named Nurse Magado, the Salinas Valley State Prison warden, C. R. Padilla, S. Gates, Secretary Ralph Diaz, and Governor Gavin Newsom as defendants. The complaint also referred to defendants at Salinas Valley State Prison and a health-care appeals office.

Washington’s claim was handwritten on one page and was difficult to read. The court could determine that he was dissatisfied with the handling of an inmate grievance identified as grievance 602. The complaint stated that the appeals branch refused to address the “real issues” and mentioned a vaccine and COVID-19. Apart from one reference to Padilla, however, Washington did not identify what any other named defendant allegedly did. The court also found the requested relief difficult to read.

Court’s Analysis

The court explained that it had to screen the complaint because the case involved governmental defendants. During screening, the court must identify claims that are legally valid and dismiss claims that are frivolous, fail to state a claim, or seek money from an immune defendant.

To state a claim under Section 1983, a plaintiff must allege both that a right under the Constitution or federal law was violated and that the violation was committed by a person acting under state authority. A defendant may be liable only if that defendant caused the deprivation of the federal right through an affirmative act, participation in another person’s act, or failure to perform a legally required act.

The court concluded that it could not determine from the complaint whether Washington had stated a valid Section 1983 claim. It directed him to file a legible amended complaint that clearly provided enough facts to state a claim against each named defendant.

Disposition

The court DISMISSED the complaint with leave to amend. Washington was ordered to file an amended complaint within 28 days of the order’s filing date. The amended complaint had to use the case caption and case number, include the words “AMENDED COMPLAINT” on its first page, and answer all questions if he used the court’s complaint form.

The court stated that the amended complaint would replace the original complaint. Claims and defendants not included in the amended complaint would no longer be part of the case. The order also directed the Clerk to send Washington two copies of the court’s complaint form with the order.