Ryant Trimble Pratt, a California prisoner proceeding pro se, sued officials at Salinas Valley State Prison under 42 U.S.C. § 1983, claiming his placement in administrative segregation based on disciplinary charges violated his constitutional rights. The case has now been dismissed twice, with Pratt failing to properly allege the specific due process violations required under Supreme Court precedent.
Judge White explained that Pratt's fundamental misunderstanding of what he needed to plead was hampering his case. "Plaintiff's claim did not fail to sufficiently allege the conditions of the segregated housing amounted to a hardship; he failed to allege what procedural protections he did not receive," White wrote. "He must do so to state a cognizable claim for relief."
The judge acknowledged that his own prior order may have contributed to Pratt's confusion. White noted that "the order of dismissal with leave to amend contains an error that may have confused Plaintiff" regarding whether he needed to address the timeliness of his claims—which he does not.
Pratt's case was originally dismissed because he failed to allege he was deprived of procedural protections required under Wolff v. McDonnell, the 1974 Supreme Court decision establishing due process requirements for prisoners in disciplinary proceedings. When Pratt filed his first amended complaint, he requested documents to show "hardship/deliberate indifference" rather than addressing the procedural due process deficiency.
Judge White emphasized that Pratt was misunderstanding the pleading requirements at this early stage. "Plaintiff is not required to make any showing, submit evidence, or provide documentation of his claims at this stage of his case," White wrote. "As explained in the order of dismissal with leave to amend, he simply needs to allege the facts of his claims."
The ruling highlights the challenges faced by pro se prisoners navigating complex constitutional claims. Under Wolff v. McDonnell, prisoners facing disciplinary action that could result in segregation are entitled to specific procedural protections, including advance written notice of charges and an opportunity to be heard before an impartial decision-maker.
Judge White has given Pratt until May 6, 2026, to file a second amended complaint that properly alleges his due process claims. The judge warned that "failure to amend within the designated time and in accordance with this order will result in the dismissal of this case."