March 16, 2026·2:24-cv-00781-MTL--·Unpublished·By Aisha Johnson
The Ninth Circuit affirmed the dismissal of a pro se prisoner's civil rights lawsuit alleging due process violations in prison disciplinary proceedings. The court held that the plaintiff failed to allege facts sufficient to state a plausible claim.
Randy Carl Eiland, an Idaho state prisoner housed in a private prison in Arizona, filed a pro se lawsuit under 42 U.S.C. Section 1983. He alleged due process violations arising from two separate disciplinary proceedings at Saguaro Correctional Center. The district court dismissed his action, and Eiland appealed.
The court’s reasoning
The panel reviewed the dismissal de novo under 28 U.S.C. Section 1915A. The court concluded that although pro se pleadings are construed liberally, the plaintiff must allege facts sufficient to state a plausible claim. The district court properly dismissed the action because Eiland failed to meet this standard.
What it means going forward
The decision reinforces that pro se litigants in civil rights cases must still allege specific facts to state a plausible claim, even when pleadings are read liberally.
