Black v. Department of State Hospitals

Background

Siva D. Black, a former patient at Napa State Hospital, filed a second amended civil-rights complaint without a lawyer under 42 U.S.C. § 1983. He alleged that he was being involuntarily medicated with antipsychotic drugs in violation of his religious beliefs. He also appeared to allege that the forced medication violated due process, which generally requires adequate procedures before the government deprives a person of a protected liberty interest.

Black identified himself as a member of the Cult of Santo Daime. He alleged that members may not be dependent on anything other than the deity and that medication interfered with his ability to have visions and communicate with higher spiritual beings. The court considered documents attached to his earlier complaints, including records from proceedings in Siskiyou County Superior Court. Those records indicated that a state-hospital doctor had diagnosed Black with schizophrenia and a psychotic disorder, testified that medication was medically necessary, and described a history of severe symptoms and impulsive aggression. The records also reflected a finding that Black had received procedures concerning involuntary medication and that untreated illness posed a serious risk to his physical or mental health.

Screening and Claims

Because Black sued a governmental entity and officials, the court screened the complaint under 28 U.S.C. § 1915A. At this stage, the court had to identify claims that could proceed and dismiss claims that were legally insufficient. The court also was required to read a complaint filed without a lawyer liberally, while still requiring enough factual allegations to make a claim plausible rather than speculative.

The court had previously dismissed Black’s original and first amended complaints with permission to amend. It concluded that the second amended complaint still did not plausibly allege a due-process violation. The court relied particularly on the records showing that Black had received ample process regarding medication. Because Black had already received opportunities to amend and further amendment was virtually certain to be futile, the court dismissed all due-process claims with prejudice.

The court separately considered Black’s religious-practice claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the First Amendment. RLUIPA generally protects a confined person from a substantial burden on religious exercise unless the government proves that the burden furthers a compelling governmental interest and uses the least restrictive means. For the First Amendment claim, the court explained that the religious belief must be sincerely held and rooted in religion, and that the government action must lack a reasonable connection to legitimate safety or institutional interests.

At the screening stage, the court assumed, while expressing reservations, that Black sincerely held his beliefs about visions and dependency and that forced medication substantially burdened those beliefs. The court stated that defendants would have to make their case that administering antipsychotic medication was the least restrictive means of serving a compelling interest. The court therefore allowed the RLUIPA and First Amendment claims to proceed; it did not make a final merits determination on those claims.

Order

The court dismissed all due-process claims with prejudice. It ordered the case to go forward against the California Department of State Hospitals, Cindy Black, Dr. Sarah J. Polfliet, and Dr. Ahmed, and directed the Clerk to issue summonses and the United States Marshal to serve the complaint and order without prepayment of fees.

The case was stayed in all other respects pending further order. Within 35 days after service, defendants were ordered to file a motion for summary judgment or another dispositive motion, supported by factual documentation and records related to the events at issue, or to inform the court if they believed the case could not be resolved by summary judgment. The order also set deadlines for Black’s opposition and any reply and stated that no hearing would be held unless the court later ordered one. Judge James Donato signed the order.