Unreported / Non-Citable
Background
Davis, a state prisoner proceeding without a lawyer, sued ten Salinas Valley State Prison correctional officers under 42 U.S.C. § 1983, seeking injunctive relief and damages. The court screened the complaint under 28 U.S.C. § 1915A(a), which requires dismissal of claims that are frivolous, malicious, fail to state a claim, or seek relief from immune defendants. Davis also filed a separate document titled Amended Complaint, which the court did not consider because Civil Local Rule 15-1 requires the entire proposed pleading without incorporating a prior one.
The following are allegations, taken as true for screening only. Davis alleged that on September 25, 2025, after he raised an enemy concern and was interviewed by three officers, he was restrained and escorted toward his cell. When he stopped walking, he alleged, Mares and Valladerez slammed him to the ground and jumped on him, Mares twisted his ankle, Hernandez assisted, and Jimenez watched without intervening. He claimed injuries to his ankle, neck and lower extremities and an asthma attack, and said he was then issued a rules violation report for battery on an officer and kept in restricted housing until December 4, 2025.
Davis further alleged that Hidalgo responded inadequately to a cellmate's weapon threat, that officers knew of an electrical hazard in front of his cell, that unspecified officers retaliated by not reporting it to supervisors, that Hill mishandled enemy concerns raised on December 4, 2025, and that Perez Pontoja and Rivera Salazar gave orders as supervisors and enforced improper training.
The Court’s Holding
Liberally construing the pro se complaint under the Twombly and Iqbal plausibility standard, the court held that Davis stated cognizable Eighth Amendment excessive force claims against Mares, Valladerez and Hernandez based on force allegedly used while he was restrained. It found a cognizable claim against Jimenez for failing to intervene, citing Robins v. Meecham. The court recited the five Bearchild v. Cobban factors but did not separately analyze them.
The failure-to-protect claims were dismissed with leave to amend. The court called the electrical hazard allegation vague and said Davis must plead where the hazard was, how long it existed, how serious it was, and which defendants knew of it and disregarded the risk. For the three enemy concerns, directed at Hidalgo, at Mares, Perez Pontoja and Rivera Salazar, and at Hill, Davis must explain the risk, including what he meant by being targeted, and why each response showed deliberate indifference under Farmer v. Brennan.
The First Amendment retaliation claim was dismissed with leave to amend because the court could not tell from the allegations whether retaliation occurred. Davis must explain how protected activity led to adverse action by specific defendants who knew of it. The court cautioned that collective shotgun pleadings are subject to dismissal under Gibson v. City of Portland. The supervisory claims against Perez Pontoja and Rivera Salazar were also dismissed with leave to amend because section 1983 has no respondeat superior liability. Davis must clarify whether they were present and ordered force, or show how their training caused the violation.
Key Takeaways
- Only the excessive force claims against Mares, Valladerez, Hernandez and Jimenez survive screening; the rest of the complaint is dismissed with leave to amend, not with prejudice.
- Davis has 28 days to file a standalone amended complaint that restates every claim without incorporating earlier filings, and if he does not, the case proceeds only on the four surviving claims.
- A failure-to-protect claim needs facts showing an objectively serious risk and that a specific defendant knew of it and failed to take reasonable steps to abate it.
- A retaliation claim must tie particular defendants' adverse actions to the plaintiff's protected conduct rather than blaming unspecified officers collectively.
- Supervisors are not liable merely for supervising; a plaintiff must plead personal involvement, causal training or policy failures, or knowing inaction.
Why It Matters
This is a screening order, not a merits ruling. The court accepted the allegations as true without finding that any force was excessive or that any defendant acted wrongfully, and it did not address the request for injunctive relief or exhaustion of administrative remedies. Nothing is resolved on the dismissed claims, and what happens to them depends on whether Davis files a compliant amended complaint.
The order is an unreported district court decision with no precedential weight. It shows how the Northern District applies Ninth Circuit pleading authority, including the 2026 Gibson decision on shotgun pleadings, and its list of missing facts gives the plaintiff a concrete roadmap. The order contains apparent clerical inconsistencies in the plaintiff's name, and this article follows the caption.