Automated Summary
Key Facts
Plaintiff Keon Andre Brackenridge, proceeding pro se under 42 U.S.C. § 1983, filed a motion to substitute John Doe Defendants with specific correctional officers. The Court granted the motion to substitute two Doe Defendants with F. Figueroa and J. Gomez, but denied the motion to add sergeant R. Valero as a defendant and to pursue official capacity claims, finding no cognizable claims against him.
Issues
- The court addressed Plaintiff's motion to substitute two John Doe Defendants with named correctional officers F. Figueroa and J. Gomez, determining whether the plaintiff established a cognizable claim for excessive force against these specific officers at the Substance Abuse Treatment Facility and State Prison, Corcoran. The court found the October 2, 2025 screening order specifically found Plaintiff stated a cognizable claim for excessive force against Defendant Does 1 and 2, correctional officers at SATF. Accordingly, the motion to substitute the two John Doe Defendants was GRANTED, and the Clerk of Court was ordered to substitute F. Figueroa and J. Gomez as the named Defendants in this action.
- The court denied the plaintiff's motion to add R. Valero as a defendant and pursue official capacity claims, finding no factual basis for claims against this officer. The court determined there are no allegations whatsoever to give rise to any cognizable claim against acting sergeant R. Valero. Additionally, the court noted there are no factual allegations linking him to any affirmative action or omission giving rise to the alleged constitutional violation. The court also held that Plaintiff cannot seek liability against Defendants in their official capacities because the Eleventh Amendment bars suits for money damages in federal court against a state, its agencies, and state officials in their official capacities.
Holdings
- The Court grants Plaintiff's motion to substitute the two John Doe Defendants with correctional officers F. Figueroa and J. Gomez as the named Defendants in this action.
- The Court denies Plaintiff's motion to add Defendant R. Valero and official capacity claims, without prejudice, as there are no factual allegations linking him/her to any affirmative action or omission giving rise to the alleged constitutional violation, and the Eleventh Amendment bars suits for money damages against state officials in their official capacities.
Remedies
The Court GRANTED Plaintiff's motion to substitute the two John Doe Defendants. The Clerk of Court shall substitute F. Figueroa and J. Gomez as the named Defendants in this action. Plaintiff's motion to add Defendant R. Valero and official capacity claims was DENIED, without prejudice.
Legal Principles
The Eleventh Amendment doctrine prohibits monetary liability claims against state officials in their official capacities in federal court. The court applied this principle to deny Plaintiff's motion to add Defendant R. Valero and official capacity claims, noting that Plaintiff cannot seek liability against Defendants in their official capacities. This is a well-established federal court limitation on sovereign immunity.
Precedent Name
Aholelei v. Dept. of Public Safety
Cited Statute
- Civil Rights Act (42 U.S.C. § 1983)
- Federal Rules of Civil Procedure Rule 15(a)
Judge Name
Stanley A. Boone
Passage Text
- The Court's October 2, 2025 screening order specifically found that Plaintiff stated 'a cognizable claim for excessive force against Defendant Does 1 and 2, correctional officers at the Substance Abuse Treatment Facility and State Prison, Corcoran (SATF).' Plaintiff was not granted leave to add or substitute new Defendants to this action, and there are no allegations, whatsoever, to give rise to any cognizable claim against acting sergeant R. Valero.
- Plaintiff cannot seek liability against Defendants in their official capacities because '[t]he Eleventh Amendment bars suits for money damages in federal court against a state, its agencies, and state officials in their official capacities.' Aholelei v. Dept. of Public Safety, 488 F.3d 1144, 1147 (9th Cir. 2007).
- 1. Plaintiff's motion to substitute the two John Doe Defendants is GRANTED; 2. The Clerk of Court shall substitute F. Figueroa and J. Gomez as the named Defendants in this action; and 3. Plaintiff's motion to add Defendant R. Valero and official capacity claims is DENIED, without prejudice.