Chagolla v. Schrag

Background

Raymundo J. Chagolla, who was incarcerated at California State Prison-Solano, filed this self-represented action under 42 U.S.C. § 1983 against officials at San Quentin State Prison, where he had previously been housed. The court stated that Chagolla had been allowed to proceed without paying the filing fee in a separate order.

Chagolla alleged that officials Schrag, Berg, Campbell, and Young placed or kept him in administrative segregation while investigating his alleged involvement in violence by the prison gang Nuestra Familia on Facility D at Pelican Bay State Prison. He alleged that Schrag placed him in administrative segregation, Berg authorized the confinement, Campbell kept him there, and Young authorized an extension. He claimed these actions negligently endangered his well-being, safety, and life, damaged his marriage, and potentially harmed his parole eligibility. He also alleged that Buckhorn wrote a memorandum concluding that Chagolla had shown loyalty to Nuestra Familia and would continue committing violence, and that Buckhorn acted negligently and maliciously. Chagolla alleged that administrative-segregation conditions were harsher than ordinary prison life. He further alleged that Robertson had access to information that could have prevented the other officials’ actions but failed to act.

Screening standard

Under 28 U.S.C. § 1915A, a federal court must screen a prisoner’s complaint seeking relief from a government entity or officer. The court must identify legally sufficient claims and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also explained that self-represented pleadings are read generously, but Federal Rule of Civil Procedure 8 still requires a short and plain statement showing entitlement to relief. A complaint cannot rely only on labels, conclusions, or a bare assertion that a defendant caused unlawful harm.

For a claim under § 1983, a plaintiff must allege both that a right secured by federal law or the Constitution was violated and that the violation was committed by someone acting under state authority.

Court’s ruling

The court dismissed the complaint with leave to amend because Chagolla had not alleged or identified any violation of federal law or the federal Constitution. The court said it would not try to determine possible causes of action from a list of factual allegations. It instructed Chagolla to identify the federal law or constitutional provision allegedly violated by each defendant and to provide specific supporting facts rather than merely using terms such as “negligence,” “due process,” or “malice.”

The court also identified legal principles that might be relevant to an amended complaint. It explained that negligence generally does not establish a constitutional violation; placement or continued placement in more restrictive housing generally does not by itself violate due process; and a supervisor is not liable under § 1983 merely because of the supervisor’s position. A supervisor claim requires facts connecting the supervisor to the alleged constitutional violation, such as facts showing that the supervisor caused the deprivation, failed to train or supervise personnel, or knew of misconduct and failed to prevent it.

The court ordered Chagolla to file an amended complaint within 28 days of the order. The amended complaint had to use the caption and case number in the order, include the words “AMENDED COMPLAINT” on its first page, include all claims and defendants he wished to pursue, and not incorporate the earlier complaint by reference. The court stated that failure to file a compliant amended complaint on time would result in dismissal of the action without further notice. The ruling was a screening dismissal and did not decide whether Chagolla ultimately had a valid constitutional claim.