Unreported / Non-Citable
Background
Plaintiff Sixto Salcido, a state prisoner proceeding pro se and in forma pauperis, filed this civil rights action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of California. He is proceeding on Eighth Amendment claims for deliberate indifference to serious medical needs after Defendants refused to renew his prescription for Gabapentin and Tramadol, which are used for pain management. The operative First Amended Complaint, filed April 20, 2026, alleges that Plaintiff was shot nearly twenty years ago and required reconstructive surgery on his face and neck, and that he took Gabapentin for chronic pain from 2004 until his prescription expired in May 2025. Plaintiff asked Defendant Oberst, a CSATF physician, to renew the prescription, but the request was not approved; Plaintiff identifies Defendant G. Ugweze as CSATF's Chief Medical Executive.
Before the Court were two motions by Plaintiff seeking transfer from the California Substance Abuse Treatment Facility (CSATF), where he is incarcerated. The first, filed July 7, 2026, requested transfer to another institution out of the county, citing an infection in his private areas and the need for a catheter installation for urinary incontinence. The second, filed August 3, 2026, sought transfer to another medical facility or institution, specifically Donovan State Prison as the closest medical facility to his family. Defendants opposed, arguing the Court lacks jurisdiction to order a transfer, that they are physicians without authority to transfer Plaintiff, and that the CDCR was not named as a defendant.
The Court’s Holding
The magistrate judge recommended that both motions be denied because Plaintiff did not meet the high burden for a preliminary injunction. A preliminary injunction requires a sufficient nexus between the claims raised in the motion and the claims set forth in the underlying complaint, and relief of the same character as that which may be granted finally. Plaintiff's transfer motions were based on a groin infection, a catheter, and a desire to be closer to his family—matters that do not concern the renewal of his Gabapentin and Tramadol prescriptions and do not involve the individual Defendants, a healthcare executive and a doctor.
The Court further found that Defendants are not responsible for Plaintiff's current medical condition, the catheter decision, or his placement, so there is no sufficient nexus between the prescription claims and the transfer motions. Even construing his mention of a Gabapentin grievance as an argument for transfer, Plaintiff had not shown that CSATF providers cannot renew his prescription; he had been housed at CSATF for over ten years and received Gabapentin until May 2025, and his stated reason for Donovan State Prison was family proximity. The Court recommended denial of the motion to transfer out of the county (ECF No. 21) and the second transfer motion (ECF No. 28).
Because this document is a recommendation under 28 U.S.C. § 636(b)(1), it goes to the assigned district judge; the parties may file objections within thirty days, and failure to object may waive the right to challenge the magistrate judge's factual findings on appeal.
Key Takeaways
- A preliminary injunction must seek relief of the same character as that which may be granted finally, with a sufficient nexus between the motion and the complaint.
- A federal court may not determine the rights of persons not before it, and non-party prison officials cannot be ordered to act on matters unrelated to the pending claims.
- Prisoner requests for prospective relief are limited by the Prison Litigation Reform Act, which requires relief to be narrowly drawn and the least intrusive means necessary.
- A magistrate judge's findings and recommendations are not final orders; parties have thirty days to object, with waiver risk for failure to object.
Why It Matters
This recommendation illustrates the limits on a court's authority to grant injunctive relief in prisoner civil rights cases: inmates cannot use transfer motions to obtain relief unrelated to the claims pled, especially where the relief would require action by non-parties such as the CDCR. It also highlights the high burden prisoners face on preliminary injunctions and the need to align requested relief with the underlying claims.
The nexus requirement from Pacific Radiation Oncology, LLC v. Queen's Medical Center was applied directly: because the transfer requests concerned an infection, a catheter, and family proximity rather than the prescription-renewal claims against the named Defendants, the magistrate judge found no authority to grant the relief and recommended denial of both motions.