Chapman v. San Mateo County

Background

Marcel E. Chapman, an inmate at Maple Street Correctional Facility, filed this action without a lawyer under 42 U.S.C. § 1983. The court reviewed his amended complaint under the federal prisoner-screening statute, 28 U.S.C. § 1915A. The amended complaint named only San Mateo County as a defendant.

Chapman alleged that on March 1, 2021, the San Mateo County Sheriff’s Office stopped all incoming inmate mail to San Mateo County correctional facilities after some inmates smuggled Suboxone through the mail. He alleged that the County consequently prohibited inmates from receiving handwritten letters. He claimed that this policy violated the First Amendment and that it violated equal protection because inmates in other counties could receive mail.

Court’s analysis

The court explained that a screening review must identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. It also explained that a § 1983 claim requires an alleged violation of a federal right by a person acting under state law.

The court held that the amended complaint stated a cognizable First Amendment claim against San Mateo County. Prisoners have a First Amendment right to send and receive mail, and Chapman alleged that an official County policy denied that right. The court therefore ordered that the First Amendment claim proceed.

The court held that the amended complaint did not state a cognizable equal-protection claim. It reasoned that Chapman had not alleged facts supporting a reasonable inference that he was similarly situated to inmates in correctional facilities in other counties. The complaint described a response to contraband being sent by mail in San Mateo County, but it was unclear whether other counties had faced similar problems. The court dismissed the equal-protection claim with leave to amend if Chapman could truthfully provide facts curing that deficiency.

Order

The court ordered the Clerk to issue a summons and directed the United States Marshal to serve San Mateo County without requiring advance payment of fees. It directed the Clerk to terminate all other defendants because the operative complaint named only San Mateo County.

The court gave Chapman 28 days from the order’s date to file a second amended complaint if he wished to pursue the equal-protection claim. Any second amended complaint had to include all claims and defendants he wished to pursue, including the First Amendment claim; it could not incorporate earlier complaints by reference. If Chapman did not file one, the amended complaint at Docket No. 16 would remain operative and the case would proceed solely on the First Amendment claim.

The court also ordered the County to file a summary-judgment motion or another dispositive motion within 91 days, unless it informed the court that summary judgment could not resolve the case. It set deadlines for Chapman’s opposition and the County’s reply, stated that no hearing would be held on the motion, and advised Chapman about the evidence needed to oppose summary judgment. The order permitted discovery under the Federal Rules of Civil Procedure and instructed Chapman to serve copies of his court filings on the County or its counsel.

Judge Haywood S. Gilliam, Jr. signed the order on April 11, 2022.