Caldwell v. Schaller, 3:14-cv-05827

Plaintiff Derek Caldwell, incarcerated at Stafford Creek Corrections Center (SCCC), alleges chronic right hip and lower back pain from an old fracture and seeks relief under 42 U.S.C. § 1983 for Eighth Amendment deliberate indifference.
Defendants moved for summary judgment; plaintiff was granted extra time to respond but did not file opposing evidence.
Medical records show intermittent complaints from 2012–2014, weight ~400+ lbs, x‑rays showing moderate–severe right hip osteoarthritis, and treatment that included x‑rays, commissary ibuprofen advice, salsalate prescription, activity restrictions (no prolonged standing, lower bunk), and weight‑loss/stretching recommendations.
DOC clinicians (PA Gregory Schaller and Dr. Sara Smith) reviewed records, approved physical therapy/home exercise, and concluded no further treatment was warranted at present aside from conservative care.
The magistrate judge concluded plaintiff at most disagrees with the chosen treatment; absence of purposeful denial or deliberate indifference warranted granting defendants’ summary judgment motion in full.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prison officials were deliberately indifferent to serious medical needs under the Eighth Amendment	Caldwell argues he was denied adequate medical care for chronic hip/back pain and needs more treatment	DOC shows examinations, x‑rays, medications (ibuprofen/salsalate), PT/home exercises, activity limits, and weight‑loss recommendations — no purposeful denial	Court held no deliberate indifference; conservative treatment was provided and plaintiff’s disagreement is insufficient for §1983 liability
Whether Stafford Creek Corrections Center (SCCC) is a proper §1983 defendant	Caldwell named institutional defendant(s) alleging inadequate care at SCCC	Defendants argue state agencies/arms of the state are not "persons" under §1983	Court noted a state agency is not a §1983 defendant and SCCC did not appear as a named defendant in the amended complaint
Whether plaintiff’s evidence raises a genuine dispute of material fact at summary judgment	Caldwell relies on his complaints/grievances and assertion that care was inadequate	Defendants submitted declarations, medical records, and a physician’s opinion; plaintiff submitted no rebuttal evidence	Court held no genuine dispute; defendants entitled to judgment as a matter of law

Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
T.W. Elec. Serv. Inc. v. Pacific Elec. Contractors Ass'n, 809 F.2d 626 (summary judgment evidence viewed in light most favorable to nonmoving party)
Lujan v. National Wildlife Fed'n, 497 U.S. 871 (conclusory affidavits insufficient)
Pena v. Gardner, 976 F.2d 469 (pro se complaints liberally construed)
Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment prohibits deliberate indifference to serious medical needs)
Parratt v. Taylor, 451 U.S. 527 (§1983 requires action by a person under color of state law)
Howlett v. Rose, 496 U.S. 356 (state entities not "persons" under §1983)
Will v. Michigan Dept. of State Police, 491 U.S. 58 (state agencies not liable under §1983)
McGuckin v. Smith, 974 F.2d 1050 (deliberate indifference analysis)
Jackson v. McIntosh, 90 F.3d 330 (deliberate indifference when officials deny, delay, or interfere with treatment)
Hamilton v. Endell, 981 F.2d 1062 (same principle re: denial/delay)
Franklin v. Oregon State Welfare Div., 662 F.2d 1337 (difference of medical opinion not §1983 violation)
Hutchinson v. United States, 838 F.2d 390 (mere negligence not Eighth Amendment violation)
Farmer v. Brennan, 511 U.S. 825 (liability when official knows of and disregards excessive risk)