Gaxiola v. Borla

Background

Joseph Emmanuel Gaxiola filed a complaint under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state authority for violations of federal rights. He alleged Eighth Amendment, due-process, and Americans with Disabilities Act claims against at least eleven defendants at Salinas Valley State Prison. The defendants included prison guards, medical staff, and grievance reviewers.

The allegations concerned different events over two years, including a prison disciplinary action; a prison guard shutting off water during a shower; retaliation; denial of medical treatment and equipment; and denial of transfer to disability housing and other disability accommodations.

Court’s analysis

Because Gaxiola sought relief from governmental employees, the court screened the complaint under 28 U.S.C. § 1915A. That screening requires a court to identify claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also explained that a § 1983 claim requires an alleged violation of a constitutional or federal statutory right by a person acting under state authority.

The court focused on the requirement in Federal Rule of Civil Procedure 20(a)(2) that claims against multiple defendants be based on the same transaction, occurrence, or series of transactions or occurrences. It held that Gaxiola’s claims involved different incidents and different defendants and therefore could not be joined in one lawsuit. The court instructed him to select one set of related claims and include any other claims closely related to those facts in an amended complaint.

The court also stated that claims against grievance reviewers could be difficult to sustain because merely reviewing an inmate grievance does not necessarily show awareness of or participation in the underlying violation. It explained that supervisors cannot be held liable under § 1983 merely because they supervise other defendants; a plaintiff must allege their participation in, direction of, or knowledge of the violations and failure to prevent them. These comments were guidance for amending the complaint, not separate merits rulings on each alleged violation.

Disposition

The court DISMISSED the complaint with leave to file an amended complaint on or before November 20, 2023. The amended complaint had to use the caption and civil case number in the order, state “FIRST AMENDED COMPLAINT” on its first page, use the court’s form, and include all allegations because it would replace the prior complaint. Gaxiola could not incorporate the prior complaint by reference. The court warned that failure to file a proper amended complaint by the deadline might result in dismissal under Federal Rule of Civil Procedure 41(b) for failure to prosecute. Judge William H. Orrick deferred ruling on Gaxiola’s motion for appointment of counsel until after reviewing the amended complaint.