Amezquita v. Garcia-Cortez

Background

Jose G. Amezquita, a state inmate proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against staff at Salinas Valley State Prison (SVSP). The court had previously found that his amended complaint stated an excessive-force claim and related state-law claims against Garcia, and a retaliation claim against Meredith; it dismissed his other claims for failure to state a claim.

Defendants Garcia and Meredith later filed a motion for summary judgment on the merits of the remaining claims. Rather than opposing that motion, Amezquita moved under Federal Rule of Civil Procedure 15(a)(2) for permission to file a second amended complaint. He then filed an “amended second amended complaint” without first receiving permission.

Proposed Second Amended Complaint

The proposed complaint kept Garcia and Meredith as defendants and added Allison, employees at R.J. Donovan Correctional Facility (RJD), and “Defendants Doe 1-10.” It alleged misconduct at RJD beginning in October 2018, including alleged efforts to intimidate Amezquita into becoming an informant, an attempted suicide, and his later transfer to SVSP. It also repeated the SVSP excessive-force and retaliation allegations and added allegations about rules-violation reports, pepper spray, and retaliation in 2023.

Defendants argued that the RJD allegations were unrelated to the 2020 claims involving Garcia and Meredith, that the proposed amendment would violate Rules 18 and 20, and that Amezquita had unjustifiably delayed seeking to add the claims while the case was already at the summary-judgment stage. Amezquita argued that the allegations described a connected series of actions by correctional staff involving the alleged “Green Wall” enterprise.

Reasons for Denying Amendment

The court explained that Rule 18 allows multiple claims against one opposing party, while Rule 20 permits defendants to be joined only when the claims arise from the same transaction, occurrence, or series of transactions and involve common factual or legal issues. The court found that the proposed complaint violated these rules because it combined claims involving different defendants, different events, and two different facilities.

The court rejected Amezquita’s attempt to connect the allegations through the alleged “Green Wall” conspiracy. It found no factual allegations showing that RJD officers in 2018 acted together with SVSP officers in 2020, or that the defendants had agreed to deprive Amezquita of his constitutional rights. The court also found that Amezquita did not provide specific facts identifying who allegedly pressured him at SVSP, what that pressure involved, or how he knew it related to his earlier litigation. Because the proposed complaint improperly joined unrelated claims and parties, the court found that allowing the amendment would be futile.

The court separately found undue delay. Amezquita did not explain why he waited more than a year after the court allowed the first amended complaint to seek the additional claims. The court also noted that he had already filed an amended complaint and had filed another “amended second amended complaint” without explaining why another amendment should be allowed.

Supplemental Pleading

The court treated the allegations about events after the original complaint as a request to file a supplemental pleading under Rule 15(d). A supplemental pleading adds events that happened after the original pleading, but the new matters must relate to the claims already in the case and cannot introduce a separate, distinct cause of action.

The court found that the allegations about rules-violation reports, 2023 pepper-spray use, and retaliation by Martinez were not related to the 2020 excessive-force and retaliation claims against Garcia and Meredith. The court also found no factual basis connecting Martinez to the alleged conspiracy. It therefore denied leave to file a supplemental pleading and stated that Amezquita could pursue those claims in separate lawsuits against the appropriate defendants.

Disposition

The court denied Amezquita’s motion for leave to file a second amended complaint and denied leave to serve a supplemental pleading. It struck the “amended second amended complaint” from the case. Because Amezquita’s deadline to oppose defendants’ summary-judgment motion had passed without another extension request, the court deemed that motion submitted and stated that it would issue a separate ruling on it later. This order did not decide the summary-judgment motion.