Hatzfeld v. Goord
9:04-cv-00159
N.D.N.Y.Nov 16, 2011Background
- Pro se plaintiff John Hatzfeld sues DOCS officials under 42 U.S.C. § 1983 for First, Eighth, and Fourteenth Amendment violations related to HCV treatment conditioned on RSAT/ASAT participation.
- Plaintiff was diagnosed with Hepatitis C and monitored by Dr. Graceffo; treatment recommended in 2002.
- DOCS revised RSAT/ASAT in late 2002 to remove religious content; plaintiff objected to continued treatment unless RSAT/ASAT was completed.
- Plaintiff refused RSAT/ASAT in 2002 due to perceived religious content; DOCS policy required RSAT/ASAT before treatment.
- Plaintiff pursued grievances; injunction granted in 2005 prohibiting conditioning treatment on RSAT/ASAT; this case consolidated with Hatzfeld II.
- Court granted summary judgment to defendants on multiple claims and found qualified immunity applicable to Eighth Amendment claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment claim viability | Hatzfeld | Defendants | Question of fact; likely denied due to later immunity ruling |
| First Amendment right to refuse RSAT/ASAT | RSAT/ASAT infringes atheist beliefs | RSAT/ASAT revised to remove religious content | Claim dismissed as to First Amendment. |
| Equal protection of HCV treatment policy | Disparate treatment vs. HIV/cancer patients; religious bias | Rational basis for RSAT/ASAT requirement | Claim dismissed; no evidence of discriminatory animus. |
| Personal involvement of Robinson and McClendon | They participated in decisions denying treatment | Not personally involved | Review unnecessary given qualified immunity and other findings |
| Qualified immunity for money damages | Might recover compensatory damages | Entitled to qualified immunity | Defendants entitled to qualified immunity; damages claim dismissed. |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (established standard for cruel and unusual punishment in medical care context)
- Martino v. Miller, 318 F. Supp. 2d 63 (W.D.N.Y. 2004) (deliberate indifference standard in medical care cases)
- Triestman v. Fed. Bureau of Prisons, 470 F.3d 471 (2d Cir. 2006) (pro se pleadings receive liberal construction but not to the point of misreading claims)
- Garrett v. Board of Trustees of Univ. of Alabama, 531 U.S. 356 (U.S. 2001) (equal protection rational basis scrutiny for classifications in prison policy)
- Isaraphanich v. Coughlin, 716 F. Supp. 119 (S.D.N.Y. 1989) (discourages discriminatory animus claims where not shown)