California Case Summaries

Raymond Baptist v. California Department of Corrections and Rehabilitation, et al. — District Court Dismisses Prisoner Civil Rights Action for Failure to State a Claim, Denies Injunctive Relief, and Closes the Case

Unreported / Non-Citable

Case
Raymond Baptist v. California Department of Corrections and Rehabilitation, et al.
Court
U.S. District Court — Eastern District of California
Judge
Jennifer L. Thurston (Joe Biden, 2021)
Date Decided
2026-10-26
Docket No.
1:26-cv-04637
Status
Unreported
Topics
prisoner civil rights, screening under 28 U.S.C. § 1915A, findings and recommendations, failure to state a claim, injunctive relief, de novo review, waiver of objections

Background

Raymond Baptist, a state prisoner, alleged that he suffered violations of his constitutional rights while housed at Corcoran State Prison, Valley State Prison, and Folsom State Prison. He filed a first amended complaint and a motion for injunctive relief on August 18, 2026, in the United States District Court for the Eastern District of California under Case No. 1:26-cv-04637 JLT BAM (PC), naming the California Department of Corrections and Rehabilitation and others as defendants.

The magistrate judge screened the first amended complaint pursuant to 28 U.S.C. § 1915A(a) and found that Plaintiff failed to state a cognizable claim for deliberate indifference to serious medical needs in violation of the Eighth Amendment, retaliation in violation of the First Amendment, and violation of the Equal Protection Clause of the Fourteenth Amendment. The magistrate judge also found that Plaintiff failed to allege compliance with the claim-presentation requirements of the Government Claims Act for any state law claims.

Because the court had already provided the relevant legal standards and Plaintiff failed to cure the pleading deficiencies, the magistrate judge determined that further leave to amend was not warranted. The magistrate judge recommended that the court dismiss the action for failure to state a cognizable claim and also recommended that Plaintiff's motion for injunctive relief be denied because he did not meet the requirements for the requested relief. The findings and recommendations issued on September 2, 2026.

The Court’s Holding

The court served the findings and recommendations on Plaintiff and notified him that any objections were due within 14 days. The court advised Plaintiff that failure to file timely objections 'may result in the waiver of the right to challenge the magistrate's factual findings on appeal,' citing Wilkerson v. Wheeler, 772 F.3d 834, 838-39 (9th Cir. 2014). Although the court granted Plaintiff an extension of time, he did not file objections and the time to do so expired.

According to 28 U.S.C. § 636(b)(1), the court performed a de novo review of the case. Having carefully reviewed the entire matter, the court concluded that the findings and recommendations were supported by the record and proper analysis. The court therefore adopted the September 2, 2026 findings and recommendations in full.

The court then entered the following operative orders: (1) the findings and recommendations issued on September 2, 2026 are adopted; (2) the action is dismissed for failure to state a cognizable claim; (3) Plaintiff's motion for injunctive relief is denied; and (4) the Clerk of Court is directed to close the case. The order is dated October 26, 2026, and closes the case entirely.

Key Takeaways

  • The district court adopted the magistrate judge's findings and recommendations after conducting de novo review under 28 U.S.C. § 636(b)(1).
  • The action was dismissed for failure to state a cognizable claim following screening of the first amended complaint under 28 U.S.C. § 1915A(a).
  • The rejected federal theories were Eighth Amendment deliberate indifference to serious medical needs, First Amendment retaliation, and a Fourteenth Amendment equal protection violation.
  • Any state law claims failed at the pleading stage because Plaintiff did not allege compliance with the Government Claims Act claim-presentation requirements.
  • Plaintiff received an extension of time but filed no objections; the court nonetheless reviewed the matter de novo, adopted the recommendations, denied injunctive relief, and directed the clerk to close the case.

Why It Matters

This order illustrates how a federal district court handles a prisoner civil rights case after magistrate-judge screening when the plaintiff files no objections. Even without objections, the court stated that it performed a de novo review and carefully reviewed the entire matter before adopting the findings and recommendations, dismissing the action, and denying injunctive relief.

The order also underscores the practical importance of timely objections to findings and recommendations. The court expressly warned Plaintiff that failure to file timely objections could waive the right to challenge the magistrate judge's factual findings on appeal, and Plaintiff's failure to object despite an extension left the recommendations unchallenged.

Read the full opinion (PDF) · Court docket

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