Standley v. Clifton

Background

Cameron Standley, an inmate at Corcoran State Prison, filed a lawsuit without a lawyer under 42 U.S.C. § 1983 against prison officials at San Quentin State Prison, where he had previously been housed. He alleged that on September 29, 2022, he refused to move cells; Justin Clifton told him he would either move willingly or be escorted; and Clifton and Loftin grabbed him. Standley alleged that he sat down, the officials fell on him, Loftin placed a knee on his neck, and Clifton pulled his arms. Backup officers arrived and shackled Standley’s feet.

Standley also alleged that Clifton and Loftin falsely reported that he had headbutted and elbowed them, resulting in a Security Housing Unit term. He said he filed a grievance and that the grievance was granted because the officials had violated his due-process rights. He further alleged that he had qualified for Level 3 housing but was denied permission to leave before the incident and was not supposed to be on a 180. He characterized his claims as excessive force, emotional distress, false accusation, false documentation, and cruel and unusual punishment. He requested compensation for pain and suffering and placement in a lower-level prison facility.

Screening standard

Because Standley was a prisoner suing government officials, the court screened the complaint under 28 U.S.C. § 1915A. Screening requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also explained that pleadings filed without a lawyer are read liberally, but still must provide more than labels, conclusions, or a bare assertion that a defendant caused harm.

To state a § 1983 claim, a plaintiff must allege both a violation of a federal constitutional or statutory right and conduct by a person acting under state authority.

Court’s analysis

The court held that the allegations did not state an Eighth Amendment excessive-force claim. The relevant question was whether the force was used in a good-faith effort to maintain or restore discipline, or instead was used maliciously and sadistically to cause harm. The court found it unclear whether Loftin briefly placed a knee on Standley’s neck after the officials fell on him or kept the knee there after Standley was already compliant in order to cause harm. The court also found it unclear how grabbing and pulling Standley’s arms amounted to an Eighth Amendment violation. It therefore dismissed the Eighth Amendment claims for excessive force and cruel and unusual punishment with leave to amend.

The court also dismissed with leave to amend Standley’s state-law claim for intentional infliction of emotional distress. It concluded that the conduct described in the complaint was not alleged with enough detail to show conduct so extreme and outrageous that it went beyond all possible bounds of decency.

The court held that the alleged false accusation of headbutting and elbowing did not itself establish a due-process violation. A prisoner generally has no constitutional right not to be falsely accused if the prisoner receives procedural due process in the resulting disciplinary proceeding. The court found no allegation that Standley was deprived of a protected liberty interest or denied procedural due process during the disciplinary proceeding. It dismissed the due-process claim with leave to amend.

The court also found that Standley’s challenge to being housed in a higher-level facility did not state a cognizable federal constitutional claim. It explained that prisoners do not have a constitutional right to confinement in a particular institution, and that a transfer within the state does not automatically create a due-process or equal-protection violation.

Disposition

The court DISMISSED the complaint with leave to amend. Standley was ordered to file an amended complaint within 28 days that addressed the identified deficiencies, used the case caption and civil case number stated in the order, and included the words “AMENDED COMPLAINT” on the first page. The order stated that an amended complaint would replace the earlier complaint and must include all claims and defendants Standley wished to pursue. It further stated that failure to file a compliant amended complaint within the time allowed would result in dismissal of the action without further notice.