Holmes v. Coffey, MD
5:25-cv-02784
N.D. Cal.Apr 14, 2025Background
- Brian Marquis Holmes, a California prisoner, filed a pro se civil rights complaint under 42 U.S.C. § 1983 against the Wardens and staff at Salinas Valley State Prison.
- Dr. Coffey prescribed Holmes a walker for his medical condition and Holmes requested a lower-tier cell to avoid using stairs with the walker.
- Holmes alleges Dr. Coffey and three other prison staff (CO Mancillas, CO Alcantar, and Nurse Nnakawuka) ignored his request, despite knowledge of his condition.
- On July 14, 2022, Holmes fell down stairs while using his walker, suffering head injury, dizziness, and pain.
- Holmes claims Defendants were deliberately indifferent to his safety and medical needs, in violation of the Eighth Amendment, and seeks damages for negligence and violations of California elder abuse protections.
- The court screened the complaint and found these allegations, when liberally construed, stated cognizable federal and state law claims, and ordered service on the named Defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment deliberate indifference | Defendants knew of risk but failed to protect him | (Not yet answered—service ordered) | States a cognizable claim for deliberate indifference |
| Negligence under state law | Defendants' inaction amounted to negligence | (Not yet answered) | States a cognizable negligence claim |
| Violation of CA Elder Abuse Act | Denial of safety/accommodation abused vulnerable adult | (Not yet answered) | States a cognizable claim under CA law |
| Service of process | Plaintiff should be permitted to serve complaint | (Not opposed) | Service permitted under CDCR e-service program |
Key Cases Cited
- Balistreri v. Pacifica Police Dep't, 901 F.2d 696 (9th Cir. 1990) (standards for liberal construction of pro se pleadings)
- West v. Atkins, 487 U.S. 42 (1988) (requirements for § 1983 claim involving state actors)
- Erickson v. Pardus, 127 S. Ct. 2197 (2007) (pro se complaints need only provide fair notice to defendants)
- Bell Atlantic Corp. v. Twombly, 127 S. Ct. 1955 (2007) (factual allegations must state a plausible claim for relief)
- Rand v. Rowland, 154 F.3d 952 (9th Cir. 1998) (summary judgment notice requirements for pro se prisoners)