Sayres v. State of California

Background

Tadashi Sayres, identified as a California prisoner, filed this civil-rights action without a lawyer under 42 U.S.C. section 1983. He alleged that defendants helped transfer more than 100 prisoners, some infected with COVID-19, from the California Institution for Men to San Quentin State Prison in May 2020. According to the complaint, defendants failed to take adequate precautions before, during, and after the transfer, including testing prisoners, screening for symptoms, distancing prisoners on buses, and testing and isolating prisoners after arrival. Sayres alleged that he became infected in late May or early June 2020 and that defendants knew of his age and African American descent as risk factors.

Sayres named the State of California, the California Department of Corrections and Rehabilitation, San Quentin State Prison, Ralph Diaz, the Estate of Robert S. Tharratt, Ronald Davis, Ronald Broomfield, Clarence Cryer, Alison Pachynski, Shannon Garrigan, Louie Escobell, Muhammad Farooq, Kirk Torres, and Does 1 through 20. He sued the people in their individual capacities. He sought declaratory relief, compensatory damages, punitive damages, and costs.

Screening and claims

Because a prisoner sued governmental entities and officials, the court screened the complaint under 28 U.S.C. section 1915A. Screening is an early review to identify claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court stated that it must read filings by people without lawyers liberally, while still requiring enough facts to make a claim plausible.

Eighth Amendment claim

The court held that the allegations concerning the transfer into San Quentin stated cognizable Eighth Amendment claims against Ralph Diaz, the Estate of Robert S. Tharratt, Ronald Davis, Ronald Broomfield, Clarence Cryer, Alison Pachynski, Shannon Garrigan, Louie Escobell, Muhammad Farooq, and Kirk Torres. A cognizable claim is one the court allows to proceed past the initial screening stage. The claims are based on alleged deliberate indifference to Sayres’s health and safety, meaning that officials allegedly knew of a substantial risk of serious harm and failed to take reasonable steps to reduce it.

California Civil Code section 52.1 claim

The court also found that Sayres stated a cognizable claim under California Civil Code section 52.1, known as the Bane Act. The court explained that the statute protects rights secured by federal or state law when interference is carried out through threats, intimidation, or coercion. Construing the complaint liberally, the court found that the alleged reckless disregard for Sayres’s constitutional rights was enough at this stage to meet the claim’s specific-intent requirement.

Rehabilitation Act claim

The court dismissed Sayres’s Rehabilitation Act claim against the State of California, the California Department of Corrections and Rehabilitation, and San Quentin State Prison. The court stated that a claim under section 504 of the Rehabilitation Act requires, among other things, that the plaintiff have a qualifying disability and that discrimination occur because of that disability. It held that Sayres had not alleged that he was disabled under the Act and that neither his African American descent nor his age of 45 qualified as a disability. The court also dismissed those three institutional defendants because Sayres had not stated a cognizable claim against them.

Negligent infliction of emotional distress

The court found that Sayres stated a cognizable claim for negligent infliction of emotional distress under California law against Diaz, the Estate of Tharratt, Davis, Broomfield, Cryer, Pachynski, Garrigan, Escobell, Farooq, Torres, and Does 1 through 20. The court explained that California does not recognize negligent infliction of emotional distress as an independent tort; the claim depends on a breach of another legal duty that proximately causes emotional distress. The court found that Sayres alleged defendants owed him a duty as a prisoner and that his emotional distress arose from their alleged breach of that duty by exposing him to COVID-19.

Order

The court ordered that the Rehabilitation Act claim was dismissed. It also ordered that the State of California, the California Department of Corrections and Rehabilitation, and San Quentin State Prison were dismissed. The court ordered service to proceed on the ten individual defendants for the cognizable Eighth Amendment, California Civil Code section 52.1, and negligent-infliction-of-emotional-distress claims.

The order directed the California Department of Corrections and Rehabilitation to report within 40 days which defendants would waive service. Defendants were ordered to file a motion for summary judgment or another dispositive motion within 90 days of service, unless they informed the court that the case could not be resolved that way. The order also set deadlines for Sayres’s opposition and defendants’ reply and authorized discovery under the Federal Rules of Civil Procedure. The order did not decide the ultimate merits of the claims that were allowed to proceed.