Matthews v. Foss
- Beth Freeman
- 5:23-cv-02800
- U.S. District Court · Northern District of California
- 5
In Matthews v. Foss, Judge Van Keulen found Ivan Lee Matthews’s Eighth Amendment claim cognizable and ordered service, allowing the case to proceed.
Ivan Lee Matthews and defendants T. Foss and M. Atchley; the order allows Matthews’s Eighth Amendment claim to proceed and directs service on the two defendants.
What happened
In Matthews v. Foss, Ivan Lee Matthews, a California prisoner representing himself, alleged that prison officials improperly placed him on suicide watch for 22 days even though he was not suicidal. He said the constant cell checks and noise caused severe sleep deprivation, high blood pressure, and pain.
The court found that these allegations stated a valid claim under the Eighth Amendment, which prohibits cruel and unusual punishment. The court ordered that T. Foss and M. Atchley be served and set deadlines for an answer and a possible motion for summary judgment or another motion that could resolve the case.
Judge Susan Van Keulen also granted Matthews’s request to mail his complaint, while a separate order granted his request to proceed without paying the filing fee. This order did not decide whether Matthews ultimately would win; it allowed the claim to move forward after initial screening.
The detailed version
- Matthews v. Foss · No. 5:23-cv-02800
- Beth Freeman
- July 14, 2023
Background
Ivan Lee Matthews, identified as a California prisoner housed at Salinas Valley State Prison, filed a complaint without a lawyer under 42 U.S.C. § 1983. He sued current and former wardens of the prison. Matthews alleged that officials placed him on suicide watch for 22 days even though he was not suicidal. According to the complaint, the watch required cell checks every 10 to 20 minutes and loud noise around the clock. Matthews alleged that he suffered extreme sleep deprivation, high blood pressure, and pain.
Matthews also alleged that he notified the defendants but they did not take reasonable steps to stop the conditions. He further alleged that the defendants failed to adequately train and supervise prison staff in administering the suicide-watch program, causing him to be placed on it erroneously.
Initial screening and ruling
The court explained that it must screen prisoner complaints seeking relief from governmental entities or their officers. At this stage, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also said that complaints filed without a lawyer must be read liberally.
The court held that Matthews’s allegations, liberally construed, stated a cognizable claim that the defendants violated his Eighth Amendment right to be free from cruel and unusual punishment. The order therefore directed that T. Foss and M. Atchley be served at Salinas Valley State Prison.
Other orders and case schedule
The court granted Matthews’s motion for leave to file the complaint by mail. It stated that his application to proceed without paying the filing fee had been granted in a separate order.
The order directed the prison system to report on whether the defendants would waive service. It required the defendant to complete a magistrate-judge jurisdiction-consent form and file an answer under the Federal Rules of Civil Procedure. It also set a deadline for a motion for summary judgment or another dispositive motion, with deadlines for Matthews’s opposition and the defendant’s reply. The order allowed discovery under the Federal Rules of Civil Procedure and reminded Matthews that he must keep the court informed of any address change and comply with court orders.
This was an order allowing the claim to proceed after screening; it did not decide the ultimate merits of the Eighth Amendment claim.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.