Muhammad v. CDCR
- Martinez-Olguin
- 3:23-cv-02242
- U.S. District Court · Northern District of California
- 3
In Muhammad v. CDCR, Judge Martinez-Olguin granted CDCR’s motion to strike Muhammad’s First Amended Complaint because it addressed another case.
Kwesi Muhammad’s First Amended Complaint was removed from this case’s docket. The California Department of Corrections and Rehabilitation obtained an order granting its motion to strike and its request for judicial notice.
What happened
In Muhammad v. California Department of Corrections and Rehabilitation, Kwesi Muhammad’s original lawsuit alleged that the California Department of Corrections and Rehabilitation discriminated against people with disabilities by changing shower access at the Correctional Training Facility. He brought claims under the Americans with Disabilities Act and Section 504 of the Rehabilitation Act and sought damages.
Muhammad later filed a First Amended Complaint alleging that CDCR denied him a second mattress because of pain and sleep problems. That filing used the case number for a separate case in the Eastern District of California and did not include the disability-discrimination allegations in this case. CDCR asked the court to strike the amended complaint, and also asked the court to take notice of records from the separate case.
Judge Araceli Martinez-Olguin granted CDCR’s motion to strike and granted its request for judicial notice. The court concluded that the amended complaint was unrelated to this lawsuit and ordered the clerk to strike it from this case’s docket and mail copies to the Eastern District of California and Muhammad.
The detailed version
- Muhammad v. CDCR · No. 3:23-cv-02242
- Martinez-Olguin
- June 14, 2024
Background
Kwesi Muhammad sued the California Department of Corrections and Rehabilitation (CDCR) in state court before the case was removed to federal court. The lawsuit alleged federal claims under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act of 1973. Muhammad alleged that CDCR discriminated against people with disabilities in April 2021 by discontinuing a practice that allowed certain people with disabilities to shower during specified times. He sought monetary damages. The court had previously found that, liberally understood, the original complaint stated claims under the ADA and Section 504.
The First Amended Complaint
On January 19, 2024, Muhammad filed a First Amended Complaint (FAC). The FAC alleged that CDCR unlawfully denied him a second mattress in October 2022 to reduce pain and improve sleep. Muhammad said he needed the second mattress because joint pain caused by his July 2021 COVID-19 diagnosis made sleeping difficult. The FAC did not include allegations about the ADA and Section 504 claims in this case. It also identified the Eastern District of California and used the case number for Muhammad’s separate case there.
Court’s reasoning
CDCR moved under Federal Rule of Civil Procedure 12(f), which allows a court to strike material from a pleading when it is immaterial or impertinent. The court also considered CDCR’s request for judicial notice, meaning recognition of the existence and contents of public court records. The court found good cause to grant that request and took judicial notice of records from the separate Eastern District case.
The court concluded that the FAC’s case number and allegations showed that Muhammad did not intend to file it in this lawsuit. Because the FAC did not relate to the claims in this case, the court found the entire FAC immaterial and impertinent to the lawsuit.
Disposition
Judge Araceli Martinez-Olguin granted CDCR’s motion to strike Muhammad’s FAC. The court also granted CDCR’s Request for Judicial Notice. It ordered the clerk to strike the FAC from this case’s docket and mail courtesy copies of the order and the FAC to the Eastern District of California and Muhammad.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.