Jones v. Lemon
- Susan Van Keulen
- 5:22-cv-07202
- U.S. District Court · Northern District of California
- 8
In Terrell Jones v. T. Lemon, Judge Van Keulen denied defendants’ dismissal motion, allowing Jones’s gender-equality claim over prison food purchases to proceed.
The ruling affects Terrell Jones and defendants T. Lemon and Howard E. Mosely, and allows Jones’s § 1983 equal-protection claim concerning Salinas Valley State Prison’s food-purchase policy to proceed.
What happened
Terrell Jones v. T. Lemon concerns Jones’s claim that officials at Salinas Valley State Prison violated equal-protection rights by stopping male prisoners from buying some sugar-based foods while allowing female prisoners to buy them. Jones sought money and an order ending the policy.
The defendants argued that the Eleventh Amendment blocked the claims and that Jones had not alleged intentional discrimination. The court rejected both arguments at this stage, finding that Jones’s allegations were specific enough to support a reasonable inference that he was treated differently because of gender. The court did not decide whether Jones will ultimately win.
Judge Susan Van Keulen denied the motion to dismiss and scheduled the defendants’ summary-judgment or other case-ending motion, along with deadlines for the parties’ filings.
The detailed version
- Jones v. Lemon · No. 5:22-cv-07202
- Susan Van Keulen
- Aug. 10, 2023
Background
Terrell Jones, a California prisoner representing himself, brought a civil-rights case under 42 U.S.C. § 1983 against Chief Deputy Warden T. Lemon and Associate Director of the Office of Appeals Howard E. Mosely at Salinas Valley State Prison. Jones alleged that prison officials denied him the ability to buy “pure sugar and sugar based products,” dried fruit, yogurt, and granola while allowing female prisoners to buy some of those items. He claimed that the policy discriminated against him because of his gender and violated the Equal Protection Clause. He sought money damages and an order ending the policy.
The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. They argued that the Eleventh Amendment barred Jones’s claims for damages and injunctive relief and that Jones had not alleged facts showing intentional, invidious discrimination.
Court’s Analysis
At the dismissal stage, the court had to accept factual allegations as true and view them favorably to Jones, while disregarding conclusory allegations and unreasonable inferences. Because Jones was representing himself, the court also had to read his complaint liberally. The court explained that it could not weigh competing explanations for the defendants’ conduct or decide whose account was ultimately more persuasive at this stage.
On the Eleventh Amendment issue, the court noted that the amendment generally protects states and state officials sued in their official capacities from certain federal lawsuits. It also recognized an exception for prospective injunctive relief against a state official and explained that officials sued in their individual capacities may be sued for damages and injunctive relief. Although Jones did not specify the capacity in which he sued the defendants, the court construed the complaint as bringing claims against them in their personal capacities. The court therefore concluded that the Eleventh Amendment did not bar the suit as pleaded.
On the discrimination issue, the court stated that an equal-protection claim under § 1983 requires allegations of intentional unlawful discrimination or facts supporting an inference of discriminatory intent. Jones alleged that the defendants enforced a policy that prohibited male prisoners like him from buying certain food items while allowing female prisoners to buy them. The court found these allegations nonconclusory and sufficient to support a reasonable inference that Jones was treated differently from similarly situated prisoners because of gender.
Ruling and Next Steps
The court denied the defendants’ motion to dismiss. This ruling allowed Jones’s equal-protection claim to continue; it did not decide the ultimate merits of the claim.
The court ordered the defendants to file a motion for summary judgment or another dispositive motion by October 16, 2023, or inform the court if they believed the case could not be resolved on summary judgment. Jones’s opposition was due November 13, 2023, and the defendants’ reply was due November 27, 2023. The court stated that the motion would be submitted on the reply deadline unless it later ordered a hearing.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.