Saddozai v. Atchley

Background

Shikeb Saddozai, a state inmate proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 against prison staff and officials at Salinas Valley State Prison and the Director of the California Department of Corrections and Rehabilitation. After the court dismissed an earlier amended complaint with leave to amend, Saddozai filed a second amended complaint.

Saddozai named L. Farley, S. Tomlinson, D. Farmer, M. Ayon, D. Cramer, and E. Heffington as defendants. He alleged that, from June 2020 through February 2022, defendants responsible for the prison law library repeatedly denied him daily access, resources, and paging services, interfering with his ability to bring legal actions and obtain meaningful access to the courts.

The complaint described three incidents. On July 21, 2020, Saddozai alleged that S. Tomlinson read, took, and kept legal documents, preventing their delivery to the court, and retaliated against him for exercising rights and filing grievances. On February 17, 2021, he alleged that Officer Berry removed him from the law library in tight handcuffs, held him for many hours in a single-person cage without water or toilet access, required him to strip naked, and issued a false serious rule-violation report. On April 6, 2021, he alleged that Correctional Officers Gonzales, Solapek, and other unnamed officers searched his cell without notice, forced him and his cellmate out, required him to strip naked, and seized legal reference materials.

Court’s analysis

The court conducted the required preliminary screening of a prisoner’s complaint against governmental entities or employees. At this stage, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a legally sufficient claim, or seek money from an immune defendant. The court also explained that a claim under Section 1983 requires an alleged violation of a constitutional or federal legal right by a person acting under state authority.

The court held that the second amended complaint violated Federal Rules of Civil Procedure 18(a) and 20(a). Rule 18(a) permits multiple claims against one opposing party, while Rule 20(a) permits multiple defendants in one action only when the claims arise from the same transaction or series of transactions and share a question of law or fact. The court found that the three incidents occurred at different times, involved different defendants, and included unrelated claims, including alleged Eighth Amendment and due-process violations. Alleging that the defendants shared retaliatory motives did not make the incidents sufficiently related.

The court also found that the complaint lacked specific facts against L. Farley, D. Farmer, D. Cramer, and E. Heffington. It stated that these defendants should be dismissed from the action for failure to state a claim against them. The opinion does not separately state a final dismissal disposition for each of those defendants apart from its ruling on the second amended complaint.

Disposition

The court ordered that the second amended complaint be DISMISSED with leave to amend. It gave Saddozai one final opportunity to file a third amended complaint correcting the identified problems. The third amended complaint must include only one of the three incidents described in the second amended complaint. Claims based on the other two incidents must be filed in separate actions, with the associated filing fees paid for each.

The third amended complaint must use the caption and case number specified in the order and state “THIRD AMENDED COMPLAINT” on its first page. It will replace the earlier complaints, and claims or defendants omitted from it will no longer be part of the case. The court warned that failure to file a proper third amended complaint within the required time would result in dismissal of the action for violating Rules 18(a) and 20(a), without further notice.