Messiah v. Garcia Lara
- Jeffrey White
- 4:22-cv-02616
- U.S. District Court · Northern District of California
- 6
In Messiah v. Garcia Lara, Judge White dismissed false-report claims but allowed excessive-force claims to proceed and ordered service.
Messiah Messiah's excessive-force and failure-to-intervene claims continue against A. Rodriguez, R. Garcia, D. Garcia-Lara, W. Welch, J. Thich, and E. Beam. His false-report claims were dismissed, and A. Andayerde and T. Haner were terminated as defendants.
What happened
Messiah Messiah, a California parolee representing himself, sued correctional officers under a federal civil-rights law over a May 2021 incident at Salinas Valley State Prison. The case is Messiah Messiah v. D. Garcia Lara, et al., No. 22-cv-02616-JSW.
Messiah alleged that four officers used excessive force and that two others failed to intervene. He also alleged that the officers filed false reports. The court found the excessive-force and failure-to-intervene claims sufficient to continue, but dismissed the false-report claims because the complaint did not allege that Messiah lacked a fair disciplinary process.
Judge Jeffrey White ordered the complaint served on six defendants and terminated A. Andayerde and T. Haner. The order also set deadlines for answers, discovery, and possible dispositive motions, including summary judgment.
The detailed version
- Messiah v. Garcia Lara · No. 4:22-cv-02616
- Jeffrey White
- Jan. 3, 2023
Background
Messiah Messiah, a California parolee proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983. The court screened the amended complaint under the federal statute requiring preliminary review of prisoner lawsuits against government entities or officials. At this stage, the court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, inadequately pleaded, or barred because they sought relief from an immune defendant.
Claims and analysis
Messiah alleged that, in May 2021 at Salinas Valley State Prison, Correctional Officers A. Rodriguez, R. Garcia, D. Garcia-Lara, and W. Welch used excessive force against him in violation of the Eighth Amendment. He also alleged that J. Thich and E. Beam witnessed the attack but failed to intervene. The court held that, when read liberally, these allegations stated cognizable Eighth Amendment claims.
Messiah also alleged that those officers, along with A. Andayerde and T. Haner, filed false reports about the incident. The court explained that filing a false report alone is not automatically a constitutional violation. It stated that a prisoner may have a civil-rights claim based on a false disciplinary report if the report was filed in retaliation for exercising a constitutional right and the prisoner was denied procedural due process, meaning a fair process such as notice and an opportunity to be heard. Because Messiah did not allege that he was denied procedural due process at the disciplinary hearing, the court found these claims not cognizable.
Ruling and next steps
The court dismissed the false-report claims for failure to state a cognizable claim for relief and terminated A. Andayerde and T. Haner as defendants. It ordered that the amended complaint and attachments be served on A. Rodriguez, R. Garcia, D. Garcia-Lara, W. Welch, J. Thich, and E. Beam through the applicable prison-service process.
The defendants were ordered to file answers under the Federal Rules of Civil Procedure. The order also directed the remaining defendants to file a motion for summary judgment or another motion resolving the case within the stated deadline, unless they informed the court that summary judgment was not appropriate. It set deadlines for Messiah's opposition and the defendants' reply, allowed discovery, and required Messiah to keep serving copies of his court filings on the defendants or their counsel.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.