Chagolla v. Schrag

Background

Raymundo J. Chagolla, an inmate at California State Prison - Solano, filed this pro se action under 42 U.S.C. § 1983 against officials at Pelican Bay State Prison, where he had previously been housed. The court screened his second amended complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner lawsuits against governmental entities or officials and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant.

Chagolla named correctional lieutenant J. Schrag, correctional counselor II J. Young, correctional counselor II B. Buckhorn, correctional captain K. Berg, and warden J. Robertson. He alleged that, in 2021, Schrag placed him in administrative segregation and that Young, Robertson, Buckhorn, and Berg kept him there based on confidential information identifying him as an associate of the Northern Structured/Nuestra Familia prison gang. Chagolla alleged that prison officials did not check the Strategic Offender Management System, which he said identified him as not being an associate of that gang. He also alleged that Buckhorn allowed the allegedly false information to be placed in his central file, creating an impression that could affect his parole prospects.

Chagolla alleged violations of the Eighth Amendment and the Fourteenth Amendment. He sought monetary damages, costs, nominal damages, and removal of the related documentation from his central file.

Court’s Analysis and Rulings

The court dismissed the Eighth Amendment claim with prejudice. It held that placement in administrative segregation, without more, does not state a claim for cruel and unusual punishment under the Eighth Amendment.

The court held that, liberally construed, Chagolla’s allegations that the evidence supporting his placement in administrative segregation was unreliable stated a cognizable Fourteenth Amendment due-process claim. The court therefore ordered service of the second amended complaint on Schrag, Young, Buckhorn, Berg, and Robertson. The order did not decide whether Chagolla will ultimately prevail on that claim.

Next Steps Ordered

The court directed service through the California Department of Corrections and Rehabilitation’s electronic-service program for prisoner civil-rights cases. It ordered the defendants to file a summary-judgment motion or another dispositive motion within 91 days after the order was filed, unless they informed the court that summary judgment could not resolve the case. It set deadlines for Chagolla’s opposition and the defendants’ reply and stated that no hearing would be held on the motion.

The court authorized discovery under the Federal Rules of Civil Procedure. It also instructed Chagolla to serve copies of his communications on the defendants or their counsel, keep the court informed of address changes, comply with court deadlines, and continue prosecuting the case. The court warned that failure to comply could result in dismissal for failure to prosecute. Judge Haywood S. Gilliam, Jr. signed the order.