Hamiltonhausey v. Broomfield

Background

Two inmates at San Quentin State Prison filed a civil-rights action under 42 U.S.C. § 1983. They were formerly proceeding without lawyers but were represented by counsel when the court screened the complaint. The plaintiffs named San Quentin Warden Ron Broomfield, California Department of Corrections and Rehabilitation Secretary Kathleen Allison, California Correctional Health Care Services Medical Executive Dr. Alison Pachynski, and CCHCS Director Joseph Bick.

The plaintiffs alleged that Broomfield and Allison approved or facilitated the transfer of approximately 121 inmates from the California Institution for Men to San Quentin without properly testing them. They alleged that Bick directed medical staff not to test the transferred inmates and expedited the transfer despite a directive from Governor Newsom to stop transfers between state prisons. They also alleged that San Quentin lacked a protocol for receiving untested inmates. According to the complaint, these actions and inactions resulted in a COVID-19 outbreak in which more than 3,000 inmates, including the plaintiffs, were infected and 29 people died. The plaintiffs referred to the transfer as occurring in 2019, but the court understood them to mean 2020.

Screening standard

Because the plaintiffs were prisoners suing governmental officials, the court was required to conduct an initial screening under 28 U.S.C. § 1915A. At this stage, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also explained that complaints filed without lawyers are read liberally, but must still provide more than labels, conclusions, or a bare assertion that defendants acted unlawfully.

To state a claim under § 1983, a plaintiff must allege both a violation of a constitutional or federal right and action by a person acting under state authority.

Court’s analysis

The plaintiffs alleged that the transfer-related conduct violated the Eighth Amendment. The court explained that prison officials violate the Eighth Amendment when they know a prisoner faces a substantial risk of serious harm and disregard that risk by failing to take reasonable steps to reduce it.

The court held that, when liberally construed, the allegations concerning the May 2020 transfer from the California Institution for Men to San Quentin stated cognizable Eighth Amendment claims. “Cognizable” means claims sufficient to proceed past the initial screening stage. The order did not decide the ultimate truth of the allegations, liability, damages, or any immunity defense.

Disposition and next steps

The court ordered service to proceed for Warden Ron Broomfield, Secretary Kathleen Allison, Dr. Alison Pachynski, and Director Joseph Bick through the California Department of Corrections and Rehabilitation’s electronic-service program for prisoner civil-rights cases. The order described procedures for waiving service and for service by the United States Marshals Service if a defendant did not waive service.

The court noted that the plaintiffs had paid the filing fee and were not proceeding without prepayment of fees. It cautioned that the Marshals Service could seek reimbursement from the plaintiffs for service costs if defendants did not waive service. The court also stated that it would issue a scheduling order for summary-judgment or other dispositive-motion briefing after related common issues were resolved in another proceeding. The order included instructions concerning communications with opposing counsel, address changes, prosecution of the case, and requests for extensions of time.