Reply Brief on Behalf of the San Andreas State Prison Authority
The State of San Andreas has granted broad authority to my client, the San Andreas State Prison Authority (SASPA), to maintain order and security within Boiling Brook State Penitentiary. For a civil suit to proceed, there must be clear and egregious misconduct on the part of my client—something the plaintiff has failed to demonstrate.
Addressing the Alleged Violations:
Fourth Amendment Violation:
The evidence shows that Ms. Ahwaih was in the custody of the Blaine County Sheriff’s Office (BCSO), where she pleaded guilty to the following charges: CC205 (Second Degree Robbery), CC401 (Resisting), and CC903 (Attempted [Offense]). After receiving due process, she was transferred to SASPA custody to serve her sentence. Upon arrival, she was provided food and water, as per standard procedure and inmate rights. There is no record indicating that the plaintiff required medical attention during or after her incarceration. Without such a need, the claim that she was denied access to medical care is unfounded.
Eighth Amendment Violation:
The plaintiff's claim of solitary confinement is contradicted by her own statements. Ms. Ahwaih had access to a phone and was able to contact individuals outside the prison, including her lawyer Ms. Cellestine. This level of communication clearly refutes any claim of isolation or cruel treatment.
Negligence:
The facility had experienced a riot within 12 hours of the events in question, necessitating BCSO intervention. When BCSO utilizes its keys, the electronic locking system resets, temporarily preventing SASPA officers from operating cell doors. This is a known issue that SASPA has repeatedly requested the State to address. The responsibility for this technical failure lies with the State, not SASPA.
Infliction of Emotional Distress:
No evidence has been presented that supports the claim that the plaintiff suffered emotional distress as a direct result of any SASPA actions. Furthermore, as previously noted, she retained the ability to communicate freely with individuals outside the prison.
Excessive Damages Demand
The plaintiff’s $902,000 demand is entirely unsupported. She presents no evidence of injury or trauma. Her incarceration followed standard procedures, and her own statements show she had phone access and contact with others. This case appears to be a baseless attempt at a payout, not a pursuit of justice.
Motion to Dismiss:
For all the reasons outlined above, the plaintiff has failed to demonstrate, either through factual evidence or legal argument, that any constitutional violation or tort occurred. Furthermore, the demand for $900,000 in damages is grossly excessive and unsupported by the facts, further underscoring the lack of merit in this case. The defense respectfully moves to dismiss the case in its entirety.
