Ronquillo v. CDCR

Background

Gabriel A. Ronquillo, identified as a state inmate, filed a complaint under 42 U.S.C. § 1983 against the “CDCR Administration,” prison chaplain Father Manuel Chavira, and officers at San Quentin State Prison. The court noted that its separate ruling on Ronquillo’s request to proceed without paying the filing fee would address that request separately.

The complaint described two attacks by other inmates. On September 20, 2022, Ronquillo alleged that he was stabbed 55 times in “Group Yard #1.” He alleged that the unnamed “gunner” on duty observed the attack begin but allowed it to continue for more than one minute. On January 14, 2023, Ronquillo alleged that Chavira placed him in a group setting at the East Block Chapel, where an inmate stabbed him six times. He alleged that an unnamed “on duty tier officer” escorted him there. Ronquillo sought damages, including punitive damages.

Screening and legal standards

Because Ronquillo sought relief from governmental defendants, the court screened the complaint under 28 U.S.C. § 1915A. That screening requires dismissal of claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also said that it must read complaints filed without a lawyer liberally.

For a claim under § 1983, a plaintiff must allege both a violation of a federal constitutional or statutory right and conduct by a person acting under state law. The court explained that the Eighth Amendment requires prison officials to take reasonable steps to protect prisoners from violence by other prisoners. A prison official is deliberately indifferent when the official knows about and disregards an excessive risk to an inmate’s health or safety by failing to take reasonable steps to address it.

Court’s analysis

The court held that, when read liberally, Ronquillo’s allegations were sufficient to state an Eighth Amendment failure-to-protect claim against the unnamed gunner responsible for “A & B Group Yard in East Block.” The alleged observation of the attack and delay in intervening supported the claim at the screening stage.

The court found the January 14, 2023 claim deficient as to Chavira and the unnamed duty tier officer. The complaint did not provide enough facts to show that either defendant knew Ronquillo faced a substantial risk of serious harm during chapel and deliberately disregarded that risk. The court allowed Ronquillo to amend that claim and directed him to try to provide sufficient supporting facts.

The court also held that the claim against the “CDCR Administration” was barred by Eleventh Amendment immunity. It explained that this immunity extends to suits against a state’s department of corrections and dismissed the claim against CDCR with prejudice.

Disposition

The court ordered:

- The claim against CDCR was dismissed with prejudice as barred by the Eleventh Amendment, and the clerk was directed to terminate CDCR as a party. - The claim arising from the January 14, 2023 incident against Chavira and the unnamed duty tier officer was dismissed with leave to amend. - Ronquillo was given 28 days from the filing date of the order to file an amended complaint. He was directed to continue trying to identify the unnamed defendants. The court stated that, if he did not amend, the claim would be dismissed with prejudice for failure to state a claim, without further notice. - The September 20, 2022 claim against the unnamed gunner was the claim that remained allowed to proceed at this stage.

The court also explained that an amended complaint would replace the original complaint, so claims or defendants omitted from the amendment would no longer be part of the action.