Chagolla v. Schrag

Background

Raymundo J. Chagolla, an inmate 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 had dismissed his initial complaint because it did not allege a violation of federal law or the federal Constitution. The court reviewed his amended complaint under 28 U.S.C. § 1915A, which requires preliminary screening of a prisoner’s claims against governmental entities, officers, or employees.

Allegations

The amended complaint named John Doe, J. Schrag, J. Young, B. Buckhorn, K. Berg, and J. Robertson as defendants, alleging that they worked at Pelican Bay State Prison. Chagolla alleged that, on August 3, 2021, Schrag placed him in administrative segregation based on confidential information gathered by John Doe, even though Schrag allegedly knew Chagolla was not part of Nuestra Familia. Chagolla further alleged that all defendants knew he was not part of Nuestra Familia but made decisions that prolonged his segregation, failed to check his file, acted negligently or with deliberate indifference, and placed false information in his file. He alleged violations of the Eighth and Fourteenth Amendments and sought $1,000 from each defendant, plus interest and costs.

Reasons for Dismissal

The court ruled that the allegations were too unclear and conclusory to state a claim. It could not determine why Chagolla was placed in administrative segregation, whether the placement involved a disciplinary or classification decision, how it would affect his parole hearing, what confidential information John Doe provided, how the defendants knew that information was inaccurate, what actions prolonged the placement, or what information was allegedly falsified. The court also said Chagolla had not identified what each defendant other than Schrag personally did or failed to do.

The court explained that placement in administrative segregation, standing alone, generally does not establish a due-process violation or cruel and unusual punishment under the Eighth Amendment. A viable claim would require more than labels such as “negligently,” “recklessly,” or “deliberate indifference.” The court also described procedural protections that may apply if Chagolla was challenging a disciplinary conviction, including notice, time to prepare, a written explanation, a limited opportunity to present evidence and witnesses, assistance when necessary, and some reliable evidence supporting the disciplinary finding.

Disposition

Judge Haywood S. Gilliam, Jr. ordered that the amended complaint be dismissed with leave to amend. Chagolla was ordered to file a second amended complaint within 28 days, using the required case caption and including all claims and defendants he wished to pursue. The court stated that failure to file a compliant second amended complaint on time would result in dismissal of the action without further notice. The order did not decide the ultimate merits of Chagolla’s constitutional claims.