Floyd v. Santa Clara Department of Correction

Background

Michael Devin Floyd, proceeding without a lawyer, alleged that his constitutional rights were violated after the San Jose Police Department (SJPD) arrested him on August 18, 2021. He alleged that, at two holding facilities, he was denied access to a bathroom and phone calls, forcibly restrained, placed in a wheelchair, and stripped naked. He brought claims against SJPD, the Santa Clara Department of Correction, the County of Santa Clara, the County of the Santa Clara Office of the Sheriff, and Elmwood Correctional Facility.

Floyd appeared to allege claims under 42 U.S.C. § 1983, a federal law allowing claims against a person who violates constitutional rights while acting under state law. The alleged claims included denial of timely bathroom and phone access, cruel and unusual punishment based on the alleged treatment at Elmwood, and a claim based on customs and policies at Elmwood. Floyd included SJPD because it arrested him and brought him to the first holding facility, whose name he did not know.

Motion and Analysis

SJPD moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally valid claim for relief. SJPD argued that Floyd had not alleged that it was involved in the events at the holding facilities. Floyd responded that he sued SJPD because it brought him to the first facility and he did not know who operated it.

The court held that Floyd had not alleged specific facts showing that SJPD employees worked at or were present in the first facility, or participated in the alleged mistreatment. The court recognized that allegations by a person representing himself are read less strictly than formal pleadings prepared by lawyers, but concluded that Floyd still had not plausibly alleged that SJPD was a person who committed the alleged violation. The court therefore granted SJPD’s motion to dismiss as to SJPD, with leave to amend.

The court did not decide SJPD’s alternative argument based on claim splitting because it concluded that Floyd failed to state a claim against SJPD. The order addressed SJPD’s motion; it did not state a disposition of the claims against the other defendants.