Caradine v. Faulder

Background

Leartis K.M. Caradine, a California prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. He sued Mendocino County Superior Court Judge Keith Faulder and the Medical Department at the Mendocino County Correctional Facility. Caradine alleged that he was not provided adequate medical care. He also asked to add the correctional facility, public defender Douglas Rhoades, and Captain Matt Kendall as defendants.

The court separately granted Caradine’s application to proceed without paying the filing fee. It then screened the prisoner complaint under 28 U.S.C. § 1915A, which requires the court to dismiss claims that are legally insufficient, frivolous, malicious, or seek money from an immune defendant.

Claims and analysis

The court held that Judge Faulder was absolutely immune from civil liability for damages based on the alleged failure to order jail officials to provide medical care. The court treated that alleged decision as an act performed in the judge’s judicial capacity. It gave Caradine leave to amend if he could, in good faith, allege facts showing that Judge Faulder acted outside his judicial capacity and violated federal law.

The court also concluded that the Medical Department and the correctional facility were not local government entities that could be sued as pleaded. It stated that the facility was a building and the Medical Department was a department within the jail. The court said Caradine could name Mendocino County instead, but he would need to allege facts plausibly showing that a county policy or custom was the moving force behind the failure to provide adequate medical care.

Regarding Douglas Rhoades, the court found that Caradine had not alleged facts showing that Rhoades, who did not work at the facility and was not a medical or supervisory employee, had authority or ability to obtain additional medical care. To state a claim against Rhoades, Caradine would need to allege such facts in an amended complaint.

Regarding Captain Matt Kendall, the court explained that a supervisor is generally liable only for the supervisor’s own misconduct, not merely for misconduct by subordinates. Caradine would need to allege facts plausibly connecting Kendall’s actions or omissions to the alleged constitutional violation, such as personal involvement or a sufficient causal connection.

Disposition

The court denied Caradine’s requests to amend the original complaint because the original complaint did not state a legally sufficient claim and the requested changes would not cure that problem. It dismissed the complaint with leave to amend. Caradine was ordered to file an amended complaint by September 30, 2022, using the case caption and number specified in the order and including the words “COURT-ORDERED FIRST AMENDED COMPLAINT.” The court stated that the amended complaint would replace the original complaint and must include all claims Caradine wished to pursue. The order also warned that failing to file a sufficient amended complaint could result in dismissal of the case. Judge Jacquelyn Corley signed the order, which disposed of docket numbers 7 and 8.