Unreported / Non-Citable
Background
Jermaine Dion Washington Jr., a detainee in the Sacramento County Jail, filed a civil rights complaint under 42 U.S.C. § 1983 in the Eastern District of California against Sacramento County Adult Correctional Health and an individual, Chevon Kothari. He alleged that the defendants violated his right to adequate medical care in several ways. According to the order's description, one set of allegations concerned inadequate care for physical injuries he says he sustained in May 2026, and another concerned insufficient care for mental health issues between June and July 2026. These are allegations only; the court made no findings about the care he actually received.
Because plaintiff is a detainee suing governmental defendants, the magistrate judge screened the complaint under 28 U.S.C. § 1915A, which directs dismissal of any portion that is frivolous or malicious, fails to state a claim, or seeks money from an immune defendant. The order applied the Twombly and Iqbal plausibility standard, which requires enough facts to make a claim plausible and does not accept legal conclusions. It also recognized that pro se pleadings are read liberally, but stressed that liberal reading cannot supply essential elements of a claim that were not pleaded. Plaintiff had also applied to proceed in forma pauperis.
The Court’s Holding
The magistrate judge dismissed the complaint with leave to amend and did not reach the merits of whether plaintiff's medical care was constitutionally deficient. The order identified three pleading problems. First, the physical-injury allegations and the mental-health allegations were unrelated, and unrelated claims may not proceed together in a suit against more than one defendant, citing George v. Smith, a Seventh Circuit decision.
Second, the complaint did not adequately explain how each named defendant was responsible for the alleged deficiencies. For the county health entity, the court explained that under Monell a local government is liable under section 1983 only when execution of its policy or custom inflicts the injury, not solely because it employs a wrongdoer, and plaintiff had not identified any specific policy or custom. Third, as to Kothari, the court said it could not tell what personal involvement, if any, that individual had in plaintiff's treatment or lack of it, so the complaint did not give fair notice of the factual basis of the claim under Rule 8.
On relief, the court granted the in forma pauperis application and ordered plaintiff, within thirty days of service of the order, to file either an amended complaint or a notice of voluntary dismissal without prejudice. The Clerk was directed to send a complaint form. The order warned that an amended complaint supersedes the original, should contain only related claims, and must be titled Amended Complaint. If plaintiff files neither, the court said it would recommend dismissal for failure to prosecute and to follow court orders, and the order states that noncompliance may result in sanctions, including a recommendation of dismissal with prejudice under Rule 41(b).
Key Takeaways
- A screening order of this kind is a dismissal with leave to amend, not a final judgment, and it does not resolve whether the underlying medical care was constitutionally inadequate.
- Plaintiffs who bundle unrelated medical complaints from different periods against multiple defendants risk having the pleading dismissed for improper joinder of claims.
- A county health entity can be liable under section 1983 only if the pleaded injury is attributable to an identified policy or custom, not merely because its personnel were involved.
- A complaint must tell each individual defendant what he or she personally did or failed to do; naming a person without describing involvement does not give fair notice.
- The thirty-day amendment deadline matters, because failure to respond could lead to a recommendation of dismissal with prejudice.
Why It Matters
This is a short, routine screening order by a magistrate judge, and it is not a reported opinion, so it carries no precedential weight. Its value is as a practical illustration of how Eastern District judges apply section 1915A to jail medical-care complaints, particularly the recurring Monell and personal-involvement gaps.
The case remains open. Plaintiff may still replead, ideally by separating unrelated claims, identifying a policy or custom for the county entity, and describing Kothari's specific role. The order did not decide whether any of those claims would succeed, did not address the standard governing a detainee's medical-care claim, and did not dismiss with prejudice. What happens next depends on whether plaintiff files an amended complaint or a voluntary dismissal within the deadline.