Unreported / Non-Citable
Background
Ryan David Anderson, who represents himself, sued Shasta County, the Shasta County Sheriff's Office, Wellpath, and a number of individual defendants under 42 U.S.C. § 1983 over alleged events at the Shasta County Jail in 2019 and 2021. The operative pleading is the third amended complaint, which the court screened under 28 U.S.C. § 1915A. The court noted that screening applies even when a plaintiff was incarcerated when the case was filed and later released. An earlier order screened the second amended complaint and found Claims 1, 2, 3, 4, 5, and 8 cognizable, along with allegations labeled Claim 9.
The following are Anderson's allegations, not findings. Claim 1 alleges two defendants wrote incident reports falsely saying he fought in February 2019, and Claim 3 alleges those reports were retaliation for grievances he filed against another defendant. Claim 2 alleges inhumane confinement conditions that caused health problems. Claims 4 and 5 assert municipal liability based on a custom or practice, and supervisory liability against four supervisory defendants. Claim 6 invokes California's Bane Act, alleging fabricated evidence, intercom harassment, interference with a call to his mother, a sham disciplinary hearing, punitive cell placement, and withheld hygiene products. Claim 7 alleges a Fourteenth Amendment due process violation because defendants did not review CCTV footage and adopted a false report. Claim 8 alleges deliberate indifference to medical needs during a January 2021 jail Covid-19 outbreak, including a physician's assistant's refusal to test him, a diagnosis four days later, and the loss of good-time credit. Claim 9 alleges a defendant retaliated by withholding or losing a hygiene package his mother sent.
The Court’s Holding
The magistrate judge recommends that the action proceed on the third amended complaint against the named defendants as to Claims 1, 2, 3, 4, 5, 7, 8, and 9. For Claims 1 through 5 and 8, the court found the re-pleaded claims functionally the same as those it had already found cognizable, and it continued to find them cognizable. Claim 7 had earlier been treated as duplicative by a different judge. Construing it now as a Fourteenth Amendment due process claim against four defendants arising from the same facts as Claim 1, the court found it cognizable. It reviewed the Wolff v. McDonnell disciplinary protections and the 'some evidence' standard, and relied on Anderson's allegations that he was not allowed to explain his conduct and that potentially exculpatory evidence was not reviewed. The court also noted that a due process challenge to loss of good-time credits belongs in habeas rather than under section 1983, but it did not apply that rule to dismiss any claim.
The magistrate judge recommends dismissing Claim 6, the Bane Act claim, with prejudice. Anderson had been told earlier that he needed to comply with the California Government Claims Act, which requires a claimant to receive a rejection or wait 45 days after presenting a claim before suing a public entity. He did not respond to that request. Concluding the deficiency could not be cured by amendment, the court recommended no leave to amend.
Key Takeaways
- These are findings and recommendations to District Judge Dale A. Drozd, not a final order; objections are due within 14 days of service and responses 14 days after that.
- Allowing claims to proceed at screening means only that the allegations are sufficient if taken as true; it is not a finding that any defendant violated Anderson's rights.
- The recommended dismissal of the Bane Act claim rests on Anderson's failure to respond to the instruction to comply with the Government Claims Act, and it would end that claim without further amendment.
- A prison disciplinary due process claim can proceed under section 1983 where success would not necessarily shorten the sentence, while challenges to lost good-time credits must go through habeas.
Why It Matters
This is an unpublished, non-precedential magistrate judge recommendation at the pleading stage, and it carries no binding weight beyond this case. Its practical effect, if adopted, is to move eight claims forward against the named defendants while ending the state-law Bane Act claim, with no further opportunity to amend.
Much remains open. The district judge must rule on any objections, the recommendation does not address defendants' responses, and the court made no finding on the merits of any allegation, including the Covid-19 and good-time-credit assertions that may face separate legal obstacles. Anderson also has a related separate action pending in this district.