Coleman v. Allen

Background

Rodney Victor Coleman, an inmate at California State Prison–Los Angeles, filed a case without a lawyer under 42 U.S.C. § 1983 concerning events at Salinas Valley State Prison, where he had previously been housed. The court reviewed the complaint under 28 U.S.C. § 1915A, which requires preliminary screening of a prisoner’s claims against governmental entities or officials. Coleman had been allowed to proceed without paying the filing fee in a separate order.

The complaint named Warden T. Allen, Lieutenant Celaya, Chief Deputy Warden Binkele, Office of Appeals Chief M. Voong, appeals examiner Captain H. Liu, CCII, and V. Lomeli. It alleged that Coleman was found guilty of 10 disciplinary violations without proof of guilt and that the findings failed to account for his mental-health condition related to paruresis, or shy bladder syndrome. The findings allegedly caused loss of various privileges. The complaint did not identify the subject of the violations, but attached grievances indicated that they involved refusing to provide urine samples in or around 2017. Coleman asserted claims under the Americans with Disabilities Act, § 1983, the Eighth Amendment, the “Coleman case,” and state regulations, and sought damages.

Reasons for dismissal

The court identified several pleading deficiencies:

- The allegations were vague and conclusory. The complaint did not explain why the cited legal provisions were violated, and the court said it could not guess the causes of action from the exhibits. - The complaint did not link any particular defendant directly to an alleged constitutional violation. - Some defendants appeared to have been named because they reviewed Coleman’s grievances. The court explained that participation in the grievance process generally does not create personal liability under § 1983 and that prisoners have no constitutional right to an effective grievance or appeal procedure. - To the extent Allen and Binkele were sued as supervisors, the complaint did not adequately allege a basis for supervisory liability. The court stated that knowledge of or acquiescence in a subordinate’s misconduct is insufficient by itself, and that an official is responsible for the official’s own misconduct. - Section 1983 does not provide liability merely for violating state law or prison policy. - The complaint did not clearly allege that Coleman was denied public services, programs, or activities because of his disability, as required for a Title II Americans with Disabilities Act claim.

Disposition

The court DISMISSED the complaint with leave to amend because it appeared that the identified problems could be corrected by alleging additional facts. The court instructed Coleman to identify the constitutional or federal right involved, name the individual who violated that right, and provide enough detail—such as the date, time, and conduct involved—to give fair notice of the claim. It directed him to avoid referring to the defendants collectively and to include all desired claims and defendants in the amended complaint, which would replace the original complaint.

Coleman had 28 days from the date of the order to file an amended complaint using the specified civil case number and the words “AMENDED COMPLAINT” on the first page. The court stated that failure to file a compliant amended complaint within that period would result in dismissal of the action without further notice.