Adams v. California Department of Corrections and Rehabilitation

Background

Forty-five current or former incarcerated people sued the California Department of Corrections and Rehabilitation and individual officers over an alleged July 20, 2020 incident at the Correctional Training Facility in Soledad. The plaintiffs alleged that officers roughly awakened them, removed them from their beds, transported them to a dining hall for holding and interrogation, and failed to address their COVID-19 safety concerns. The plaintiffs also alleged race discrimination and various civil-rights and state-law claims, including claims under Sections 1983, 1985, and 2000, the California Ralph Act and Bane Act, and state tort law.

The defendants’ motion challenged four matters: COVID-19 claims by all plaintiffs except Lawrence Brown; the COVID-19 class claims; the race-discrimination class claim; and the plaintiffs’ excessive-force claims under the Fourth Amendment.

COVID-19 claims

The court applied Rule 12(b)(6), which asks whether the complaint alleges enough facts to make a claim legally plausible. The defendants argued that Shelton Adams and Frederick Brinkley, who were proposed class representatives, could not plausibly connect their COVID-19 infections in October and November 2020 to the July incident. The plaintiffs argued that the incident began a viral outbreak that spread through the facility over the following months.

The court held that the amended complaint did not adequately explain how Adams’s or Brinkley’s later exposure resulted from the July incident rather than from other possible sources. Because this was the plaintiffs’ second attempt to allege causation, the court dismissed the COVID-related portions of their Sections 1983 and 1985 claims and their state-law battery claim without leave to amend. The court also dismissed the COVID-19 allegations within the Section 2000 claim without leave to amend.

Class claims

The defendants argued that Adams and Brinkley were unsuitable class representatives for the COVID-19 claims and that the proposed class lacked sufficiently similar claims and typical representatives for the race-discrimination claim. The court stated that these class-suitability issues generally should not be decided through a motion to dismiss and are better addressed during class certification, especially because discovery had not yet begun and no class-certification motion had been filed.

The provided text expressly states that the motion to dismiss the COVID-19 class claims was denied. For the race-discrimination class claim, the provided excerpt states that the issue was better addressed during class certification but does not include a separate express disposition sentence.

Excessive-force claims

The plaintiffs brought their excessive-force claims under the Fourth Amendment, but did not directly refute the defendants’ argument that convicted incarcerated people must bring such claims under the Eighth Amendment. The court therefore dismissed Claims I and II with leave to amend.

Disposition

The court granted in part and denied in part the defendants’ motion to dismiss. It dismissed COVID-19 Claims III, IV, and X without leave to amend, and dismissed the COVID-19 allegations within Claim V without leave to amend. It dismissed Claims I and II with leave to amend. The plaintiffs could file an amended complaint within 28 days, limited to correcting the deficiencies identified in the order. The order states that failure to amend on time would result in dismissal of the relevant claims with prejudice.