King v. Macay

Background

Rashad Lamar King, a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 based on conditions at Salinas Valley State Prison. He alleged that, from February 13, 2020, through April 17, 2020, his cell repeatedly flooded and had plumbing problems, leaving the cell covered with feces, urine, and sewage. He also alleged that he was using crutches because of an ankle injury, that officials denied his request for a different cell, and that he fell while trying to flush his toilet with a bucket. He claimed ongoing pain and other effects from the fall and exposure to unsanitary conditions.

King named Correctional Sergeants C. Tange and E. Macay, Chief Deputy Warden E. Borla, Warden M. Atchley, and Associate Warden John Doe #1 in their individual and official capacities. He sought injunctive relief, monetary damages, and punitive damages. He alleged that Macay and Tange failed to address the plumbing and flooding, that Tange ignored his requests for help after his fall, that Borla and John Doe #1 reviewed his grievance without remedying the conditions, and that Atchley knew about the conditions but failed to correct them.

Screening and claims recognized

Because King sought relief from prison officials, the court screened the complaint under 28 U.S.C. § 1915A. At this stage, the court had to identify claims that could proceed and dismiss claims that were legally insufficient or sought money from an immune defendant. The court was required to read a complaint filed without a lawyer liberally.

The court found that the complaint stated a cognizable Eighth Amendment claim against Macay and Tange for deliberate indifference to King’s serious medical needs. The court also found a cognizable Eighth Amendment claim against Macay and Tange for deliberate indifference to King’s health and safety based on the alleged sewage, flooding, lack of sanitation, and related conditions. It found the same type of health-and-safety claim against Borla and John Doe #1 based on their handling of King’s appeals. The court additionally found a cognizable supervisory-liability claim against Atchley.

A cognizable claim is one that has enough alleged facts to proceed past initial screening; it is not a final determination that the allegations are true or that King will ultimately win. The order did not decide the ultimate merits of the claims.

John Doe defendant and service

The court permitted King to proceed against John Doe #1 while recognizing that King had not yet identified that defendant by name. The court ordered King to provide the name of John Doe #1 by the deadline for dispositive motions. If he failed to do so, the court stated that John Doe #1 would be dismissed without prejudice to King filing a new action against that defendant once the name became known.

The court ordered service on C. Tange, E. Macay, E. Borla, and M. Atchley through the California Department of Corrections and Rehabilitation’s electronic-service process for prisoner civil-rights cases. It also set deadlines for answers, possible dispositive motions, responses, and replies, and permitted discovery under the Federal Rules of Civil Procedure.

Disposition

Judge Donna M. Ryu did not dismiss the complaint at screening. The court recognized the claims described above, ordered service on Tange, Macay, Borla, and Atchley, and required King to identify John Doe #1 by the stated deadline. The order is a preliminary screening and case-management ruling, not a final decision on liability.