Meyers v. Kernan

Background

Leon Lee Meyers, who was formerly incarcerated at Salinas Valley State Prison and was incarcerated at Wasco State Prison when he filed the case, brought a civil-rights action under 42 U.S.C. § 1983. He represented himself and paid the filing fee. The court reviewed the complaint under the federal prisoner-screening statute, 28 U.S.C. § 1915A.

Meyers alleged that officials at Salinas Valley violated his Fourteenth Amendment right to equal protection by denying him release under a COVID-19-related medical-release program, the Elderly Parole Program, and California Proposition 57. He also alleged First Amendment retaliation based on cell searches, his transfer to Wasco, and an administrative classification identifying him as a violent sex offender after he helped another inmate file grievances and a lawsuit.

Meyers further alleged that the classification and transfer placed his safety at risk in violation of the Eighth Amendment. His remaining Wasco-related allegations included lost or damaged property, denial of requested disability accommodations, interference with law-library access, repeated cell searches, and exposure to COVID-19 risks. He also filed a motion seeking a preliminary injunction requiring officials at Wasco to provide single-cell housing.

Screening of the Salinas Valley Claims

The court dismissed the Fourteenth Amendment equal-protection claim without leave to amend. It explained that Meyers had not identified a protected class or alleged that defendants treated him differently from similarly situated prisoners. The court also concluded that:

- Proposition 57 provides early-parole consideration to people convicted of nonviolent felony offenses, and Meyers’s convictions for assault, battery, and causing great bodily injury made him ineligible under the statute. - The Elderly Parole Program required at least 20 years of continuous incarceration on the current sentence, while the court found that Meyers had served 12 years. - The medical-release allegations did not show that Meyers was treated differently from similarly situated prisoners. The complaint’s materials indicated that most prisoners considered eligible were not released.

The court dismissed Meyers’s First Amendment retaliation claim without leave to amend. It reasoned that the challenged actions occurred before officials could have learned that Meyers had helped another inmate. The court noted that the cell searches occurred before the other inmate’s complaint was served on Officer Mendez, that the transfer was ordered before the searches and service of the complaint, and that the challenged classification already appeared in Meyers’s record before those events. The court also noted that the alleged searches covered every cell, which suggested a legitimate prison-related purpose rather than retaliation.

The court dismissed the Eighth Amendment claims concerning Meyers’s classification and transfer without leave to amend. It concluded that the classification was supported by the cited California regulations and Meyers’s prior arrest and convictions. It further held that, even if the classification were incorrect, misclassification alone did not violate the Eighth Amendment. Regarding the transfer, the court reasoned that Meyers’s proposed safer housing arrangement would also house general-population prisoners and that the records showed he had already been housed in general population at Salinas Valley.

Transfer of the Remaining Claims

The court stated that its analysis disposed of all claims concerning events at Salinas Valley, while the remaining claims concerned events at Wasco. Because Wasco is in Kern County, which lies in the Eastern District of California, the court found that venue for those remaining claims and the requested injunction was proper there rather than in the Northern District of California.

Under 28 U.S.C. § 1406(a), the court ordered the action transferred to the United States District Court for the Eastern District of California and directed the clerk to transfer the matter. The order did not state that the transferred claims were dismissed.