Mackey v. Broomfield
- Beth Freeman
- 5:22-cv-04341
- U.S. District Court · Northern District of California
- 4
In Mackey v. Broomfield, Judge Freeman dismissed Mackey’s amended civil-rights case as duplicative of his earlier related case.
Michael Mackey’s amended civil-rights action and the named prison and medical defendants; the order dismissed this action, terminated pending motions, and closed the file.
What happened
In Mackey v. Broomfield, Michael Mackey, a state prisoner representing himself, challenged the transfer of 122 prisoners to San Quentin State Prison during the COVID-19 pandemic and the outbreak that followed. He sought damages from prison and medical officials.
The court had previously found Mackey’s original complaint insufficient and allowed him to amend it. The amended complaint described alleged failures to test and isolate transferred prisoners, worsening prison conditions, and other failures, but the court determined that the action repeated the same allegations and requested relief from an earlier related case involving the same defendants or people legally connected to them.
The court dismissed the complaint as duplicative, ordered the clerk to terminate pending motions, and closed the file. Judge Beth Labson Freeman issued the order.
The detailed version
- Mackey v. Broomfield · No. 5:22-cv-04341
- Beth Freeman
- Apr. 27, 2023
Background
Michael Mackey, a state prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983. His original complaint alleged that San Quentin State Prison should have placed prisoners in single cells because of COVID-19. The court dismissed that complaint because it did not adequately allege an Eighth Amendment violation, but allowed Mackey to amend.
Amended Complaint
The amended complaint challenged the March 30, 2020 transfer of 122 prisoners from CIM to San Quentin. Mackey alleged that the prisoners were not tested before the transfer, that some were symptomatic when they arrived, and that they were not properly isolated. He also alleged that the resulting outbreak and the prison’s failure to reduce its population contributed to prolonged lockdowns, extreme solitary confinement, and cramped and dirty cells. He sought damages and named prison and medical officials, among others.
Duplicative-Action Ruling
The court said Mackey had previously filed an action in the same district involving the same allegations and seeking damages. That earlier related case was proceeding with counsel and was stayed while an appeal on certain issues was pending. Applying the rule against duplicative litigation, the court found that both actions arose from the same core events—the alleged transfer and handling of prisoners infected with COVID-19 from CIM to San Quentin—and that the defendants in both cases were parties or legally connected to parties in the earlier action.
Disposition
The complaint was DISMISSED as duplicative. The clerk was ordered to terminate all pending motions and close the file. The opinion does not state whether the dismissal was with or without prejudice.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.