Unreported / Non-Citable
Background
Clarence Lonnel Roberson, a state prisoner proceeding pro se, filed a civil rights action under 42 U.S.C. § 1983 against Jason Schultz and unnamed Doe defendants. Roberson alleged that on January 5, 2026, he was assigned to a cell that had not been cleaned prior to his entry, and that as a result he contracted a fungal infection resistant to treatment. The complaint was subject to mandatory screening under 28 U.S.C. § 1915A(a), which requires federal courts to identify cognizable claims and dismiss any portion that is frivolous, malicious, fails to state a claim, or seeks monetary relief from an immune defendant.
The court outlined the applicable pleading standards: a complaint must contain a short and plain statement showing entitlement to relief under Federal Rule of Civil Procedure 8(a)(2), and must allege enough facts to state a claim that is plausible on its face under Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal. While pro se complaints are construed liberally under Haines v. Kerner, a court may not supply essential elements of a claim that were not initially pled. The plaintiff also filed an application to proceed in forma pauperis (ECF No. 5).
The Court’s Holding
The court held that Roberson's complaint fails to meet federal pleading standards because it does not describe how the named defendant, Jason Schultz, was personally responsible for the alleged injury. Citing Skaff v. Meridien N. Am. Beverly Hills, LLC, the court emphasized that a complaint must give the defendant fair notice of the factual basis of the claim. The complaint's failure to link Schultz to the unclean cell assignment or the resulting infection rendered it insufficient under Rule 8 and the plausibility standard.
Accordingly, the court dismissed the complaint with leave to amend. Roberson was ordered to file an amended complaint or a notice of voluntary dismissal within thirty days of service of the order, using the complaint form provided by the Clerk. The court warned that failure to comply may result in sanctions, including a recommendation of dismissal with prejudice under Federal Rule of Civil Procedure 41(b). The court granted Roberson's application to proceed in forma pauperis.
Key Takeaways
- A prisoner's § 1983 complaint must allege specific facts linking each named defendant to the claimed constitutional violation; mere identification of a defendant is insufficient.
- The court applied the Twombly/Iqbal plausibility standard and Ninth Circuit precedent requiring personal involvement for § 1983 liability.
- Dismissal with leave to amend is the standard remedy for a pro se prisoner's first deficient complaint under § 1915A screening.
- The plaintiff must file an amended complaint on the court-provided form within thirty days or face potential dismissal with prejudice for failure to prosecute.
- In forma pauperis status was granted, allowing the case to proceed without prepayment of fees.
Why It Matters
This order illustrates the rigorous application of pleading standards in prisoner civil rights cases at the screening stage under § 1915A. Even with liberal construction afforded to pro se litigants, courts require factual allegations that plausibly connect each defendant to the alleged harm. The decision reinforces that supervisory liability or respondeat superior theories are insufficient without personal involvement, and it sets a clear deadline and procedural roadmap for amendment. The grant of IFP status ensures the plaintiff can pursue his claims without financial barrier, but the burden remains on him to cure the pleading deficiency.