David Pride, Jr. v. M. Correa
2013 U.S. App. LEXIS 14353
| 9th Cir. | 2013Background
- Pride, a California state prisoner, sues under 42 U.S.C. § 1983 alleging deliberate indifference to serious medical needs at Calipatria State Prison.
- He seeks damages and, crucially, injunctive relief for his own medical treatment denied by a Chrono Committee.
- The district court dismissed Pride's injunctive-relief claim as duplicative of the ongoing Plata v. Brown class action for systemic prison medical care reform.
- Pride’s claim centers on a Chrono Committee’s denial of a knee brace and related care prescribed by his treating physician after transfer from Pelican Bay.
- The Plata stipulation sets up systemic reforms and a separate framework (involving a 602 process and non-treatment-specific channels) but does not expressly provide for individualized medical relief.
- On appeal, Pride challenges the district court’s dismissal, arguing his injunctive relief is not duplicative of Plata and should proceed separate from the class action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Pride's injunctive-relief claim duplicative of Plata? | Pride’s relief is individualized medical care, not systemic reform. | Plata controls the relief; individualized relief is encompassed by Plata. | Not duplicative; Pride may pursue his individualized injunctive relief claim. |
| Is Pride's injunctive-relief claim moot as to Dr. Levin? | Continued denial of treatment may persist regardless of Levin's transfer. | Levin’s transfer moots the claim against him. | Remand for mootness determination; potential amendment to name current responsible officials. |
| Do Plata stipulations bar Pride’s individualized injunctive relief? | Plata does not preclude individualized relief for Pride. | Stipulation provides mechanisms that could preclude such relief. | Plata does not preclude Pride’s individualized relief; dismissal reversed. |
Key Cases Cited
- Crawford v. Bell, 599 F.2d 890 (9th Cir. 1979) (district court may dismiss duplicative class claims but not independent ones)
- Krug v. Lutz, 329 F.3d 692 (9th Cir. 2003) (consent decrees do not bar independent, individualized relief when not conclusively addressed)
- Burnett v. Dugan, 618 F. Supp. 2d 1232 (S.D. Cal. 2009) (individualized relief may proceed where Plata is not the proper vehicle)
- Brown v. Plata, 131 S. Ct. 1910 (2011) (overcrowding necessitated systemic reform; Plata detailed background of remedies)