Washington v. San Mateo County Board of Supervisors
- Haywood Gilliam
- 4:22-cv-01347
- U.S. District Court · Northern District of California
- 3
Judge Gilliam dismissed Washington v. San Mateo County Board of Supervisors’s complaint with leave to amend because it did not link defendants to the mail policy.
DeAndrea Washington and the defendants she named, including the San Mateo County Board of Supervisors and the individual defendants.
What happened
In DeAndrea Washington v. San Mateo County Board of Supervisors, DeAndrea Washington, an incarcerated person representing herself, alleged that the San Mateo County Sheriff’s Office stopped all incoming inmate mail after unidentified inmates smuggled a Suboxone film strip through the mail.
The court screened Washington’s civil-rights complaint and found that it identified a sheriff’s-office policy but did not explain what actions any named defendant took or how the defendants were connected to that policy. The court also noted that Washington had not said whether she completed the required administrative process before filing suit.
Judge Haywood S. Gilliam, Jr. dismissed the complaint with leave to amend. Washington was given 28 days to file an amended complaint addressing these problems; failing to do so would result in dismissal of the action without further notice.
The detailed version
- Washington v. San Mateo County Board of Supervisors · No. 4:22-cv-01347
- Haywood Gilliam
- Apr. 11, 2022
Background
DeAndrea Washington, an inmate at Maguire Correctional Facility, filed a self-represented action under 42 U.S.C. § 1983. She named the San Mateo County Board of Supervisors, Dave Pine, Carole Groom, Don Horsely, Warren Slocum, and David Cianepa as defendants. She alleged that on April 4, 2021, the San Mateo County Sheriff’s Office stopped all incoming mail to inmates at the facility after unidentified inmates, with no connection to Washington, smuggled a Suboxone film strip through the mail. She alleged that she was unable to receive postal mail.
Screening and pleading requirements
Because Washington was a prisoner seeking relief from governmental defendants, the court reviewed the complaint under the Prison Litigation Reform Act’s screening requirement, 28 U.S.C. § 1915A. The court explained that a complaint must identify a legally protected right that was violated and a person acting under state authority who caused the violation. It also explained that a self-represented complaint is read generously but still must provide enough information to give defendants fair notice of the claims.
The court found that the complaint identified a policy of the San Mateo County Sheriff’s Office but did not identify actions taken by the named defendants or connect those defendants to the policy. The court also noted that Washington had not indicated whether she exhausted available administrative remedies before filing suit, as required for covered prisoner claims.
Disposition
The court DISMISSED the complaint with leave to amend. Washington was ordered to file an amended complaint within 28 days addressing the identified deficiencies. The amended complaint had to use the required caption and case number, state all claims and defendants she wished to pursue, and not incorporate the prior complaint by reference. The court stated that failure to file a proper amended complaint within the allotted time would result in dismissal of the action without further notice. The order did not decide whether the mail policy violated Washington’s constitutional rights.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.