United States of America, United States District Court of the Eastern District of California, 11 March 2022, No. 1:21-cv-01093-DAD-EPG (PC)
Case overview
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Case ID
Decision date
Deciding body (English)
Type of body
Type of Court (material scope)
Type of jurisdiction
Type of Court (territorial scope)
Instance
Area
Vulnerability groups
Outcome of the decision
General Summary
The Plaintiff, an inmate housed at a Substance Abuse Treatment Facility claimed he had been infected with Covid-19 due to a lack of care by Defendants, who were officially responsible for his well-being, safety, and health. The claim was based on Eighth Amendment conditions of confinement. The Defendants filed a motion to dismiss and a request for judicial notice based on qualified immunity and the fact that the Plaintiff’s allegations did not show deliberate indifference of their actions or any violation of the Eighth Amendment.
The Court reasoned that "It is undisputed that the treatment a prisoner receives in prison and the conditions under which [the prisoner] is confined are subject to scrutiny under the Eighth Amendment." Regarding the judicial notice, "[t]he Court may judicially notice a fact [*14] that is not subject to reasonable dispute because it: (1) is generally known within the trial court's territorial jurisdiction; or (2) can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned." It concluded that while those facts were relevant to the Plaintiff's claims going forward, they were not relevant to deciding whether the Plaintiff had stated a claim or whether the Plaintiff's complaint should be dismissed. Therefore, the Court recommended that the Defendants' request for judicial notice be denied.
The Court also found that the law clearly established that individuals in government custody have a constitutional right to be protected against a heightened exposure to serious, easily communicable diseases, and that this clearly established right extended to protection from COVID-19. Therefore, it recommended that the motions to dismiss based on qualified immunity or absence of a violation of the Eighth Amendment should be denied. It also concluded that the motion to dismiss the declaratory relief requested by the Plaintiff should be granted in this phase of the process.
Facts of the case
The Plaintiff was housed at the Substance Abuse Treatment Facility, where Defendant Stuart Sherman was the Warden and Defendant Lopez was a Correctional Lieutenant in Facility F. The Plaintiff argued that correctional officers in the facility would not wear their face masks, therefore they knew or should have known that this put the Plaintiff at a substantial risk of contracting COVID-19. The Plaintiff alleged that Defendants took no precautions to protect him from COVID-19. They did not enforce six-feet of social distancing, they did not enforce their policy that staff had to wear masks, they did not provide sanitation materials to disinfect common areas, and they turned the facility, which was a non-infected facility, into a quarantine, which infected inmates and which put inmates in the facility at risk of catching COVID-19, including the Plaintiff. The Plaintiff was then infected with COVID-19 and suffered symptoms like a shortness of breath and headaches, which could cause irreparable and permanent harm to him.
Type of measure challenged
Measures, actions, remedies claimed
Individual / collective enforcement
Nature of the parties
Claimant(s)
Private individualDefendant(s)
Public
Type of procedure
Reasoning of the deciding body
The Court analyzed the motion to dismiss and the request for legal notice filed by Defendants and reasoned that:
1) Two requirements must be met to show an Eighth Amendment violation. "First, the deprivation alleged must be, objectively, sufficiently serious." Second, "a prison official must have a sufficiently culpable state of mind," which for conditions of confinement claims "is one of deliberate indifference."
2) In determining whether a defendant is entitled to qualified immunity, the Court must decide whether the facts shown by the plaintiff make out a violation of a constitutional right; and whether that right was clearly established at the time of the officer's alleged misconduct.
The Court found that the Plaintiff had sufficiently alleged that Defendants were aware of the danger of COVID-19, yet took no actions to protect him (and in fact turned a non-infected facility into a quarantine, which infected all inmates in that facility, including the Plaintiff). Therefore, the Court found that Defendants' request to dismiss the Plaintiff's claim based on the first prong of qualified immunity analysis should be denied.
The Court also reasoned that, when the actions (or inactions) of Defendants occurred in this case, the law was clearly established that individuals in government custody have a constitutional right to be protected against a heightened exposure to serious, easily communicable diseases, and that this clearly established right extended to protection from COVID-19. The Plaintiff sufficiently alleged that Defendants did not protect him from COVID-19 in any way, and thus the Plaintiff had sufficiently alleged that Defendants violated a clearly established right. Therefore, the Court found the Defendants' request to dismiss the Plaintiff's claim based on the second prong of qualified immunity analysis should be denied.
Finally, Defendants argued that the Plaintiff's request for declaratory relief should be dismissed because there was no ongoing controversy, and that the request was redundant and unnecessary. Since the Plaintiff agreed with Defendants that his request for declaratory relief at this stage was unnecessary and did not oppose Defendants' request to dismiss his claim for declaratory relief, the Court recommended this motion to dismiss be granted.
Conclusions of the deciding body
The Court partially granted the motion to dismiss filed by Defendants.
Fundamental Right(s) involved
Fundamental Right(s) instruments (constitutional provisions, international conventions and treaties)
Rights and freedoms specifically identified as (possibly) conflicting with the right to health
Balancing techniques and principles (proportionality, reasonableness, others)
The Court did not use balancing techniques, and based the decision on case law and an interpretation of the Plaintiff’s constitutional rights.
