Granados v. Monterey County Jail
- Jeffrey White
- 4:23-cv-01504
- U.S. District Court · Northern District of California
- 4
In Granados v. Monterey County Jail, Judge White dismissed the complaint with leave to amend because the named defendant cannot be sued.
John Anthony Granados must file a properly amended complaint within 28 days to continue pursuing his claims. The order also identifies the County of Monterey, another responsible government entity, or individual jail officials as possible defendants if properly named and supported by factual allegations.
What happened
In Granados v. Monterey County Jail, John Anthony Granados, who was representing himself, claimed that jail officials placed him in harsh solitary confinement, failed to provide medical care, and held him after his release date.
The court said these allegations could support a claim under the Eighth Amendment if Granados named a proper defendant. But he named only Monterey County Jail, which the court described as a physical structure that cannot be sued.
Judge White dismissed the complaint with leave to amend and gave Granados 28 days to file a replacement complaint naming a responsible government entity or individual officials and explaining their involvement.
The detailed version
- Granados v. Monterey County Jail · No. 4:23-cv-01504
- Jeffrey White
- May 18, 2023
Background
John Anthony Granados, a California parolee proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. He alleged that, while detained at Monterey County Jail for a resentencing hearing, jail officials placed him in solitary confinement for about three months, from June 2022 through September 13, 2022. He said he was confined 23 to 24 hours a day, had no light in his cell, had no contact with other people, and received no treatment for diagnosed anxiety and depression. He also alleged that officials kept him in jail for 16 days after he was ordered released on August 28, 2022, and that he was later diagnosed with a cognitive disorder he did not have before arriving at the jail.
Screening and Claims
The court conducted the preliminary review required for complaints seeking relief from a governmental entity or officer. The court said that, when read liberally, Granados’s allegations would state a proper Eighth Amendment claim if he named a defendant that could be sued. Granados said he was suing jail officials, but he named only Monterey County Jail. The court held that the jail was merely a physical structure and was not a suable entity.
The court explained that Granados could name the County of Monterey or another government entity responsible for the jail, but he would need to allege that a policy, practice, or custom caused the alleged constitutional violations. He could also name individual jail officials, but he would need to explain what each official did or failed to do regarding the alleged confinement conditions, lack of due process, lack of medical care, or detention beyond his release date.
Ruling
Judge White ordered that the complaint be DISMISSED with leave to amend. Granados was ordered to file an amended complaint within 28 days. The amended complaint had to use the caption and case number specified in the order and include the words “COURT-ORDERED FIRST AMENDED COMPLAINT” on its first page. The court stated that an amended complaint replaces the original complaint, so Granados could not incorporate the original complaint by reference. The court also stated that failure to amend as required would result in dismissal of the case. This was a preliminary screening order and did not decide the ultimate merits of the alleged constitutional violations.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.