Unreported / Non-Citable
Background
Pedro Luis Madrigal, a state prisoner incarcerated at Richard J. Donovan Correctional Facility at the time of filing, filed a pro se civil rights complaint under 42 U.S.C. § 1983 together with a motion to proceed in forma pauperis. The court found the IFP motion complied with 28 U.S.C. § 1915(a)(1) and (2) because it was accompanied by an inmate trust account statement and a prison certificate, granted the motion, and assessed an initial partial filing fee of $39.41 under § 1915(b)(1). The order directs the Secretary of the CDCR, or the Secretary's designee, to collect that initial fee and thereafter forward monthly payments from Madrigal's account to the Clerk of the Court under § 1915(b)(2).
Madrigal sued CDCR reviewing authorities M. Kibbee and Moeckly, alleging that they violated his constitutional right of access to the courts when they reviewed, processed, or denied his CDCR 602 grievances challenging the agency's failure to timely refer his case for resentencing consideration under California's SB 483. He sought compensatory damages and $150,000 in punitive damages. He is serving a sentence of 95 years to life, and his own exhibits showed that CDCR submitted his name to the Los Angeles County sentencing court in January 2026; the complaint does not indicate whether or not that sentence has been modified following the referral.
Because Madrigal was a prisoner proceeding IFP, the court screened the complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A(b), applying the same plausibility standard used for a Rule 12(b)(6) motion to dismiss for failure to state a claim.
The Court’s Holding
The court dismissed the complaint in its entirety under 28 U.S.C. §§ 1915(e)(2)(B)(ii) and 1915A(b)(1) for failure to state a claim, but without prejudice and with sixty days' leave to file a First Amended Complaint. It first held that prisoners have no independent constitutional right to a particular grievance or appeal procedure, so Kibbee and Moeckly could not be liable merely for processing Madrigal's grievances. It also held that he did not allege any affirmative act or legal duty connecting these reviewing authorities to the SB 483 identification-and-referral obligation, which the statute assigned to the CDCR Secretary and county correctional administrators.
The court further held that the access-to-courts claim failed because Madrigal did not plausibly allege actual injury: his own exhibits showed his case was referred for resentencing in January 2026, and he did not allege that he was unable to file or defend any action or that he lost an otherwise available remedy. Construed liberally as a due process claim, the complaint was also not cognizable under § 1983 under Heck v. Humphrey, because a damages judgment would necessarily imply the invalidity of a conviction or sentence that had not been reversed, expunged, declared invalid, or called into question by habeas relief.
The operative disposition was mixed: the IFP motion was granted, the CDCR Secretary or designee was directed to collect the partial fee and forward payments, the Clerk was directed to serve the order, and the complaint was dismissed without prejudice with leave to amend rather than by final judgment.
Key Takeaways
- Prison officials who merely review, process, or deny inmate grievances are not liable under § 1983 absent an independent constitutional violation or personal participation in the alleged deprivation.
- An access-to-courts claim requires plausible allegations of actual injury, such as the inability to file a complaint, meet a deadline, or present a nonfrivolous claim.
- A prisoner's own exhibits can defeat an access-to-courts theory when they show that the underlying legal process, such as a resentencing referral, remained available.
- Damages claims that would necessarily imply the invalidity of an existing conviction or sentence are not cognizable under § 1983 unless the conviction or sentence has first been invalidated.
- A pro se prisoner complaint dismissed at screening may still receive leave to amend unless the pleading deficiencies clearly cannot be cured.
Why It Matters
The order reinforces two recurring limits on prisoner civil rights litigation: grievance processing alone does not create constitutional liability, and access-to-courts claims require concrete litigation prejudice rather than frustration with administrative handling.
It also illustrates how Heck v. Humphrey can bar § 1983 damages claims arising from delayed resentencing referrals when the prisoner's sentence remains intact, even if state law later made the challenged enhancements legally invalid.