Jones v. Rahimi

Background

Monroe Jones alleged that Deputy Rahimi, identified in the opinion as a correctional deputy with the San Mateo Sheriff’s Department, used excessive force against him on October 26, 2022. Jones also alleged that Rahimi had him placed in administrative segregation in retaliation for filing grievances. Jones brought the claims under 42 U.S.C. § 1983, a federal law that provides a cause of action for violations of federal rights by people acting under state law.

Screening and Claims

The court reviewed the complaint under 28 U.S.C. § 1915A(a), which requires preliminary screening of a prisoner’s complaint seeking relief from a governmental entity or officer. The court explained that it must identify claims that are legally sufficient and dismiss claims that are frivolous, malicious, fail to state a claim, or seek relief from an immune defendant. It also stated that it must read self-represented pleadings liberally.

The court found that, when liberally construed, Jones had stated two cognizable claims against Rahimi: an Eighth Amendment excessive-force claim and a First Amendment retaliation claim. The court dismissed all other claims and defendants. It specifically stated that Jones’s medical-care claims did not attach liability to any person because the complaint did not identify the individuals responsible. The court noted that Jones could seek permission to amend if he learned those individuals’ names.

Orders and Procedure

The court ordered the Clerk to issue a summons and directed the United States Marshal to serve Rahimi, without requiring advance payment of fees, with the complaint, its attachments, and the order. The court also directed the Clerk to send courtesy copies to the California Attorney General’s Office.

Rahimi was ordered to file, by July 10, 2023, a motion for summary judgment or another dispositive motion addressing the claims found cognizable. If Rahimi sought dismissal based on Jones’s alleged failure to exhaust available administrative remedies, the court directed him to present that argument in a summary-judgment motion. The court stated that summary judgment could not be granted, or qualified immunity found, if material facts were disputed.

Jones’s opposition was due 45 days after Rahimi filed the motion, and Rahimi’s reply was due 15 days after the opposition. The motion would be considered submitted when the reply was due, and no hearing would be held unless the court later ordered one. The court authorized discovery under the Federal Rules of Civil Procedure and provided instructions about service, address changes, extensions of time, prosecution of the case, and the notice Rahimi must give Jones explaining how to oppose a summary-judgment motion.

Disposition

This was an order screening the complaint and allowing specified claims to proceed; it was not a decision on whether Jones ultimately proved those claims. The court dismissed all other claims and defendants and ordered service and further proceedings on the excessive-force and retaliation claims. Judge Liam H. Orrick signed the order on April 5, 2023.