Sheldon v. San Quentin Staff

Background

Jeff Sheldon, a state prisoner incarcerated at Wasco State Prison, filed a civil-rights action under 42 U.S.C. § 1983 based on allegations concerning his incarceration at San Quentin State Prison from 2018 through 2023. He named “San Quentin Staff,” “The Torture Squad,” “Top Secret Torture,” “Premeditated Torture,” several identified prison employees, and unnamed California employees and correctional officers. He sought money damages for what he described as “torture by technology.”

The court stated that it would grant Sheldon permission to proceed without paying the filing fee in a separate written order. It then conducted the required preliminary screening of a prisoner complaint seeking relief from government employees.

Reasons for dismissing the complaint

The court found that the complaint was not manageable in its current form. It determined that Sheldon’s allegations of “torture by technology,” as pleaded, were factually frivolous. It also found that the complaint was argumentative, excessively repetitive, and largely irrelevant, failing to provide the short and plain statement required by Federal Rule of Civil Procedure 8.

The court identified additional pleading deficiencies:

- Sheldon did not directly connect each named defendant to a specific alleged constitutional violation. - Some defendants were mentioned only in conclusory terms. - The allegations appeared to rely on improper supervisor liability, meaning liability based only on a person’s supervisory position rather than personal involvement or a sufficient causal connection. - The complaint potentially combined claims involving different incidents, people, and events over more than five years. The court instructed Sheldon that claims and defendants may be joined only when they arise from the same transaction or related series of events and involve common questions of law or fact. - Sheldon provided almost no information about whether he had completed the required prison grievance process before filing suit. The court therefore could not determine whether his claims were exhausted. It stated that the claims might be unexhausted and subject to dismissal.

Unnamed defendants

Sheldon also attempted to sue unnamed “California employees” and “California Correctional Officers” at San Quentin State Prison. The court found that he had not described or linked these unnamed defendants to particular constitutional violations. It dismissed the claims against the unnamed defendants with leave to amend. If Sheldon could not provide their names, he was required to give specific descriptions and explain how each person was connected to his allegations. Otherwise, the court stated that those defendants would be dismissed without prejudice to filing a new action against them.

Required amended complaint

The court dismissed Sheldon’s complaint with leave to amend. It required any amended complaint to use the court’s prisoner civil-rights form, state each claim in a separate numbered paragraph, identify each defendant’s specific action or failure to act, identify the resulting injury, explain exhaustion as to each claim and defendant, and include only properly joined claims. The amended complaint could not exceed 40 pages and could not rely on allegations based solely on a supervisor’s position.

Sheldon was given 28 days from the order to file the amended complaint. The court stated that failing to meet the deadline or correct the identified deficiencies would result in dismissal of the action without prejudice. The amended complaint would completely replace the original complaint and could not incorporate the original complaint by reference.

Request for appointment of counsel

The court construed Sheldon’s “Request for Investigator” as a request for appointment of counsel and denied that request for lack of exceptional circumstances. The denial was without prejudice to the court appointing counsel at a later date if circumstances warranted it.

Disposition

The court dismissed the complaint with leave to amend, dismissed the claims against the unnamed defendants with leave to amend, denied the request for appointment of counsel, and directed the Clerk to send Sheldon a blank civil-rights form and a copy of the order.