Baker v. Atchley

Background

Timothy Ray Baker filed a civil-rights complaint under 42 U.S.C. § 1983. He alleged that Richard Garcia, a correctional officer at Salinas Valley State Prison, used excessive force against him on or about July 8, 2021. The complaint named more than 15 other defendants, including the warden, deputy warden, other supervisors, and grievance reviewers. Baker also moved for a preliminary injunction based on alleged excessive-force incidents involving Garcia and another correctional officer.

Screening of the Complaint

Because Baker sought relief from governmental officers, the court screened the complaint under 28 U.S.C. § 1915A. The court concluded that, when liberally construed, the complaint stated a cognizable Eighth Amendment excessive-force claim against Garcia.

The court dismissed all other claims and defendants. Baker described only one event in detail, and the court found that this was insufficient to hold other defendants liable for allegedly failing to protect him from Garcia. The court also explained that grievance reviewers are not responsible for an underlying violation merely because they ruled against a prisoner on an administrative complaint. Baker’s claims against supervisors also could not proceed because the complaint did not show their personal involvement, direction, knowledge, or failure to act regarding the alleged violation. The court stated that § 1983 does not impose automatic liability on a supervisor for an employee’s conduct.

Preliminary Injunction

The court denied Baker’s motion for a preliminary injunction. Baker described one incident involving Garcia in the complaint, but did not provide sufficient detail in the motion about that incident. The motion also mentioned, without sufficient detail, an August 2022 incident involving Officer Tanori. The court found that the incidents, as described, were insufficient to grant preliminary relief at that time.

Orders and Next Steps

The court ordered service of the complaint on Garcia and directed Garcia to respond to the cognizable claim. The court ordered Garcia to file a summary-judgment motion or another dispositive motion—meaning a motion that could resolve the claim—or notify the court that the case could not be resolved that way, by June 12, 2023. If Garcia argued that Baker failed to complete required prison grievance procedures, that argument had to be made through a summary-judgment motion.

The court set deadlines for Baker’s opposition and Garcia’s reply, stated that no hearing would be held unless later ordered, and allowed discovery under the Federal Rules of Civil Procedure. It also reminded Baker of his responsibilities to prosecute the case, keep the court informed of address changes, and comply with court orders. Only the claims against Richard Garcia were allowed to proceed; all other claims and defendants were dismissed. The clerk was directed to terminate the other defendants and the docket entry for Baker’s preliminary-injunction motion.

Judge William H. Orrick signed the order on March 3, 2023.