Keith Lake v. Leroy Baca

MEMORANDUM

Keith Lake appeals from three orders by the district court that resulted in the entry of summary judgment for the defendants on his action filed pursuant to 42 U.S.C. § 1983 based on his over-detention and defendants’ alleged attempt to coerce a settlement of his claim for over-detention. We affirm.

The district court found that Lake had not alleged that the named defendants had (1) any personal involvement in his over-detention, (2) any direct contact with him, or (3) actual knowledge of his incarceration. Nonetheless, Lake argues that even though the defendants had no personal involvement in his over-detention, they could still be individually liable if he shows a causal connection between their wrongful acts and the constitutional violation. See Redman v. County of San Diego, 942 F.2d 1435, 1446 (9th Cir.1991) (en banc). Here, the district court properly determined that Lake had not adequately alleged such a connection. See Ashcroft v. Iqbal, — U.S.-,-, 129 S.Ct. 1937, 1949 , 173 L.Ed.2d 868 (“In a § 1983 suit or a Bivens action—where masters do not answer for the torts of their servants—the term ‘supervisory liability’ is a misnomer. Absent vicarious liability,…