Unreported / Non-Citable
Background
Plaintiff Keonte Gathron, an inmate at the San Francisco County Jail proceeding pro se, filed a civil rights complaint under 42 U.S.C. § 1983 against Deputy Lei (badge #2584) and Deputy McCollum (badge #7615). He paid the filing fee. The court was required to conduct a preliminary screening under 28 U.S.C. § 1915A(a) to identify cognizable claims or dismiss the complaint if frivolous, malicious, or failing to state a claim. Pro se pleadings are to be liberally construed.
Gathron alleged that the defendants escorted him back to his cell while he was "belly chained and leg shackled." After he responded "no" to their question about whether his criminal proceedings had ended, Deputy Lei said, "Fuck you, motherfucker." The deputies shut the cell door and left him in the restraints for approximately three and a half hours. As a result, Gathron sustained a wrist fracture, sprain, and bruising. He also alleged that a request for information from jail medical personnel went unanswered and that a deputy falsely told him the defendants would be transferred, but he did not allege the named defendants were involved in those incidents.
The Court’s Holding
The court applied the standard for excessive force claims by pretrial detainees under the Fourteenth Amendment, citing Kingsley v. Hendrickson, 576 U.S. 389 (2015), which requires showing that force purposely or knowingly used was objectively unreasonable. The court liberally construed Gathron's allegations as claiming that the defendants used excessive force by applying restraints in a manner that caused significant injuries. The court concluded that the complaint states a claim capable of judicial determination against the defendants for excessive force in violation of the Fourteenth Amendment right to due process.
Accordingly, the court ordered the Clerk to issue a summons and the U.S. Marshal to serve the complaint, attachments, and this order on both deputies at the San Francisco County Jail without prepayment of fees. A courtesy copy was directed to the San Francisco City Attorney's Office. The court also set an expedited schedule: defendants must file a motion for summary judgment or other dispositive motion by January 26, 2027, with supporting documentation and incident records; plaintiff's opposition is due by February 23, 2027; and defendants' reply is due by March 9, 2027. The motion will be deemed submitted on the reply due date with no hearing unless ordered. Discovery may proceed under the Federal Rules without further court order.
Key Takeaways
- The court found that a pretrial detainee's allegation of being left in belly chains and leg shackles for three and a half hours, resulting in a wrist fracture, sprain, and bruising, states a plausible excessive force claim under the Fourteenth Amendment's objective unreasonableness standard from Kingsley v. Hendrickson.
- Pro se prisoner complaints are liberally construed at the screening stage under 28 U.S.C. § 1915A, and the court may infer a cognizable claim from factual allegations even if not artfully pleaded.
- The court ordered service on the individual deputies at the jail and set a firm briefing schedule for summary judgment, requiring defendants to produce all records and incident reports from the events at issue.
- Defendants must serve the Rand v. Rowland notice on the plaintiff with their dispositive motion, warning the pro se litigant of the consequences of failing to oppose summary judgment with evidence.
- The court noted that the plaintiff did not allege the named defendants were involved in the unanswered medical request or the false statement about deputy transfers, so those allegations did not support a claim against Lei or McCollum.
Why It Matters
This order illustrates the application of the Kingsley objective standard for pretrial detainee excessive force claims at the § 1915A screening stage. The court's willingness to infer an excessive force claim from the duration and manner of restraint use—rather than a discrete act of violence—shows that conditions of confinement and restraint practices can support a plausible claim. The expedited schedule and requirement that defendants produce all incident records with their summary judgment motion reflect the court's active case management in prisoner civil rights cases. The order also demonstrates the procedural protections afforded pro se litigants, including the Rand notice requirement and liberal construction of pleadings.