Unreported / Non-Citable
Background
Michael Jace, a state prisoner proceeding pro se, sued eight Corcoran State Prison employees under 42 U.S.C. § 1983. He alleged that rules violation reports (RVRs) issued or approved over roughly two years were retaliation for his grievances and lawsuits. The case was transferred from the Central District of California in June 2026. On August 5, 2026, the court screened the original complaint and found no cognizable claim. It was a long narrative of unrelated RVRs, did not say which acts were retaliatory or why, alleged no link to specific protected conduct, and violated Rules 18 and 20. It was also subject to the Heck bar to the extent it attacked guilty findings. Jace was given leave to amend.
Jace filed a first amended complaint on September 17, 2026. It dropped Lieutenant Barrios and named seven defendants. In Claim 1 he alleges that before June 12, 2024, he overheard Officer Reynoso refer to him as the one filing grievances and lawsuits. He alleges Reynoso then issued him an RVR for refusing a cellmate but issued none to other inmates who also refused. Claims 2 through 7 allege that Ruiz, Bresno, Curnel, Duffy, Cid and Gonzalez retaliated through later RVRs, an unnecessary interview, and a failure to follow an Office of Appeals directive to investigate an alleged confidential memorandum. He seeks punitive and exemplary damages from each defendant. These are allegations, and the court made no findings on their truth.
The Court’s Holding
This is a screening order and set of findings and recommendations under 28 U.S.C. § 1915A, not a final judgment. Magistrate Judge Erica P. Grosjean found that, for screening purposes only, Jace sufficiently alleges that Reynoso retaliated against him for protected grievance and litigation activity. The court relied on the alleged overheard remark, Reynoso's alleged awareness of the Office of Appeals' directive to investigate the memorandum, and the alleged selective issuance of an RVR. It recommends that the case proceed on that claim alone.
As to Ruiz, Bresno, Curnel, Duffy, Cid and Gonzalez, the court said the claims are subject to the Heck bar to the extent success would necessarily imply the invalidity of guilty findings that may have cost good-time credits. It did not find that the bar actually applies. The operative ground for its recommendation is Rules 18 and 20. The claims involve different defendants and different conduct over two years, and a shared retaliation theory does not make them related. The court recommends dismissal without prejudice to filing separate actions, and no further leave to amend, because Jace reasserted the same unrelated claims after receiving guidance. A footnote says the 2024 and 2025 events raise no apparent limitations problem. By order, the Clerk is directed to terminate Barrios as a defendant.
Objections are due within thirty days, and the matter is referred to the assigned district judge. Until that judge acts, the recommended dismissals are not entered, and the retaliation claim against Reynoso has been tested only at the pleading stage.
Key Takeaways
- A retaliation claim can pass screening where the plaintiff alleges the officer referred to his grievances and lawsuits, knew of an investigation, and selectively disciplined him.
- Passing screening does not mean the allegations are proven. The court assumed them true only to decide whether the claim may proceed.
- Heck may bar damages claims that would necessarily imply the invalidity of disciplinary findings affecting good-time credits. Here the court applied it only conditionally, and the recommended dismissal rests on joinder.
- Claims against different defendants over different incidents belong in separate lawsuits, and a common retaliation theory does not satisfy Rule 20.
- The dismissals are recommended, are without prejudice, and leave Jace free to file separate actions on the unrelated claims.
Why It Matters
The order shows how a district court can narrow a sprawling prisoner complaint to one viable claim without ruling on the underlying disciplinary disputes. It enforces Rules 18 and 20 while preserving the dismissed claims for separate suits, which reduces the risk of limitations problems.
Because it is an unadopted magistrate recommendation, it carries no precedential weight. Its value is as an example of the screening approach used in the Eastern District of California. What remains open is the district judge's ruling on objections and, for the Reynoso claim, the merits.