Sanchez Martinez v. Freitas

Background

Julio Cesar Sanchez Martinez, an inmate at Santa Cruz County Jail, filed this self-represented action under 42 U.S.C. § 1983. The court reviewed the complaint under the federal prisoner-screening statute, 28 U.S.C. § 1915A. That screening requires a court to identify claims that are legally sufficient and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek damages from an immune defendant.

The complaint named Santa Cruz County Jail correctional officials as defendants. It challenged a new mail policy requiring people who send mail to jail inmates to send it to Smart Communications in Florida. Smart Communications scans the mail, makes it available on electronic tablets, and destroys it after 30 days. The complaint alleged that inmates were not given a full explanation of the policy, that one tablet was available for every six inmates, that inmates could print only eight pages per month for free, and that some inmates controlled access to the tablets. The complaint also alleged that the defendants agreed to and implemented the policy despite Sanchez Martinez’s complaints. He requested $1,000 from each defendant.

Claims and analysis

The court concluded that, liberally construed, the allegations that the policy deprived Sanchez Martinez of his physical mail stated a cognizable Fourteenth Amendment due process claim involving the deprivation of personal property. A “cognizable” claim is one that is legally sufficient to proceed at the screening stage; it is not a final determination that the plaintiff will prevail.

The complaint also asserted a First Amendment right-to-receive-mail claim. The court dismissed that claim with leave to amend. The court explained that prisoners have a First Amendment right to send and receive mail, but Sanchez Martinez reported accessing his mail through the tablets and did not allege that he personally had received no mail. The court further stated that he could not sue on behalf of other inmates who allegedly lacked tablet access. It allowed amendment so he could clarify how receiving mail electronically violated his own First Amendment rights.

Order and effect

The court ordered the clerk to issue summonses and directed the United States Marshal to serve the operative complaint and the order on the named jail officials concerning the cognizable Fourteenth Amendment claim. The court also ordered case-management procedures for later dispositive motions, including deadlines for any summary-judgment motion, Sanchez Martinez’s opposition, and defendants’ reply. The order stated that discovery could proceed under the Federal Rules of Civil Procedure.

The First Amendment claim was dismissed with leave to amend. Sanchez Martinez was given 28 days from the order’s date to file an amended complaint addressing the identified deficiencies. The order stated that an amended complaint would replace the original complaint and must include all claims and defendants he wished to pursue. If he did not timely file an amended complaint, the original complaint would remain the operative complaint. The order did not decide the ultimate merits of either claim.