Background
Randy Carl Eiland, an Idaho state prisoner housed in a private prison in Arizona, appealed pro se from a district court judgment dismissing his action under 42 U.S.C. Section 1983. Eiland alleged substantive due process violations arising from his refusal to report to the medical department.
The court’s reasoning
The court reviewed the dismissal de novo under 28 U.S.C. Section 1915A. It held that although pro se pleadings are construed liberally, the plaintiff must allege facts sufficient to state a plausible claim. The court cited precedent stating that substantive due process forbids the government from depriving a person of life, liberty, or property in a way that shocks the conscience or interferes with rights implicit in ordered liberty. The court found Eiland failed to meet this standard.
Substantive due process forbids the government from depriving a person of life, liberty, or property in such a way that shocks the conscience or interferes with the rights implicit in the concept of ordered liberty.
Corales v. Bennett, 567 F.3d 554, 568 (9th Cir. 2009)
What it means going forward
The decision reinforces the requirement that pro se prisoners must allege specific facts to state a plausible substantive due process claim, even when pleadings are construed liberally.
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