Maury v. Seamon

Background

Robert E. Maury, a California prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983 against officials at San Quentin State Prison and the California Department of Corrections and Rehabilitation. The opinion states that he was separately granted permission to proceed without paying the filing fee.

Maury alleged that C. Seamon removed him from his prison job after previously reducing his pay rate. He claimed that Seamon violated provisions of the California Code of Regulations and the prison’s Departmental Operations Manual. He also alleged that Broomfield and Gipson failed to adequately supervise or train Seamon, allowing Seamon to be negligent in his duties. In addition, Maury alleged that his administrative grievances were not properly handled.

Screening standard

Because Maury sought relief from governmental officials, the court screened the complaint under the federal prisoner-screening statute, 28 U.S.C. § 1915A. That statute requires the court to identify claims that may proceed and dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also explained that complaints filed without a lawyer are read liberally, but they still must contain enough factual allegations to state a plausible claim.

To state a claim under 42 U.S.C. § 1983, a plaintiff must allege both that a right under the Constitution or federal law was violated and that the violation was committed by a person acting under state authority.

Court’s reasoning

The court held that violations of state law, a prison operations manual, and the state-law tort of negligence do not themselves establish violations of federal law. It therefore concluded that Maury’s claims were not legally cognizable under Section 1983.

The court further held that amendment would be futile. It explained that there is no constitutional right to a prison job or prison rehabilitation, and no constitutional right to an administrative grievance system. According to the court, neither Maury’s loss of a prison job nor the alleged ineffective handling of his grievances violated federal law.

Disposition

The court dismissed the case for failure to state a claim upon which relief may be granted. It did not grant Maury leave to amend. The clerk was directed to enter judgment and close the file. Judge Jeffrey S. White signed the order.