David Peasley v. M. Spearman, 18-56648

Plaintiff David Peasley, a California prisoner with Type 1 diabetes, sued prison staff under 42 U.S.C. § 1983 alleging deliberate indifference to serious medical needs.
The district court granted summary judgment dismissing most claims; Counts 6 and 9 were dismissed and appealed.
Count 6: Peasley filed a CDCR Form 602 complaining that security officers (Lopez, Orozco, Balli, Gibson) denied him medical care; his appeal was bounced between the Inmate Appeals Office and the Health Care Appeals Office with conflicting rejection letters.
The appeals offices gave inconsistent guidance about whether jurisdiction depends on the subject (medical vs. custody) or the staff involved, and instructed him to refile with the other office, effectively foreclosing a clear path to relief.
Count 9: On Sept. 16, 2013, after a medical appointment where Peasley received insulin, Officer Lopez denied him entry to his building at lunch; Peasley had crackers in his pocket but did not tell Lopez he had just taken insulin or explicitly state a medical need.
The Ninth Circuit reversed the dismissal of Count 6 (administrative remedies effectively unavailable) and affirmed dismissal of Count 9 (no genuine dispute Lopez knew of a serious medical need).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Peasley’s failure to exhaust administrative remedies bars Count 6	Peasley: appeals process was opaque and gave conflicting instructions, making remedies effectively unavailable under the PLRA	Defendants: Peasley failed to properly appeal; administrative remedies were available and not exhausted	Reversed — administrative scheme was so opaque (conflicting rejections/referrals) that remedies were effectively unavailable; remanded
Whether Officer Lopez was deliberately indifferent by denying lunch entry (Count 9)	Peasley: Lopez knew or should have known he was diabetic and had previously asked for urgent medical help; circumstantial evidence (Lopez’s knowledge of diabetics keeping crackers) supports a finding she knew of his medical need	Lopez: Peasley never told her he had just taken insulin or needed food for medical reasons on Sept. 16; no direct evidence she was subjectively aware of a serious medical need	Affirmed — no genuine dispute of material fact that Lopez was subjectively aware of a serious medical need at that moment; summary judgment proper

Ross v. Blake, 578 U.S. 632 (2016) (administrative schemes can be so opaque that remedies are effectively unavailable under the PLRA)
Albino v. Baca, 747 F.3d 1162 (9th Cir. 2014) (availability exception to PLRA exhaustion where remedies are effectively unavailable)
Fuqua v. Ryan, 890 F.3d 838 (9th Cir. 2018) (grievance detail required is defined by prison procedures)
Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates the Eighth Amendment)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires subjective awareness of substantial risk)
Lolli v. County of Orange, 351 F.3d 410 (9th Cir. 2003) (officers may be found aware of diabetic emergency from detainee’s complaints and symptoms)