Iniguez v. Newton, 3:16-cv-02601

Plaintiff Jose Iniguez, a state prisoner, sued Dr. Patricia Newton under 42 U.S.C. § 1983 alleging retaliation and deliberate indifference related to medical care and accommodations.
Alleged retaliation: Newton approved two of four requested accommodations, denied two, and refused to refer Iniguez for a second surgery he previously declined.
Alleged Eighth Amendment claim: deliberate indifference to serious medical needs based on denial/partial denial of requested treatments and accommodations.
Magistrate Judge Peter Lewis issued a Report & Recommendation (R&R) recommending dismissal; no party filed objections to the R&R within the ordered time.
District Court reviewed and adopted the unobjected-to R&R, added further analysis, and granted Newton’s motion to dismiss, dismissing the action with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retaliation for filing administrative appeal	Newton denied some accommodations and a surgery referral as punishment for appeals	Denials were medical judgments/legitimate penological actions, not retaliation	Dismissed — denials implausible as retaliation; consistent with legitimate penological reasons
Deliberate indifference to serious medical needs	Newton’s denials/partial denials amounted to conscious disregard of substantial risk	Newton believed requested treatments unnecessary and provided some treatment (orthopedic shoes, pain meds)	Dismissed — plaintiff failed to allege defendant knew and drew inference of substantial risk; disagreement over treatment is medical judgment, not deliberate indifference
Sufficiency of complaint after R&R with no objections	Rely on R&R findings and additional facts alleged in complaint	Rely on R&R reasoning and additional legal analysis showing deficiencies	Court adopted and slightly modified R&R; dismissal with prejudice affirmed
Standard of review for unobjected R&R	Not directly contested by parties	District court may review but is not required to de novo absent objections	Court reviewed R&R, found it correct, and adopted it

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state plausible claim; implausible allegations insufficient)
Thomas v. Arn, 474 U.S. 140 (1985) (district courts not required to conduct de novo review when no objections to magistrate judge’s report)
United States v. Reyna-Tapia, 328 F.3d 1114 (9th Cir. 2003) (en banc) (statutory text does not mandate de novo review absent objections)
Watison v. Carter, 668 F.3d 1108 (9th Cir. 2012) (retaliation claim requires showing absence of legitimate penological reason for adverse actions)
Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate indifference requires subjective awareness of substantial risk)
Estelle v. Gamble, 429 U.S. 97 (1976) (medical treatment decisions are matters for medical judgment; negligent treatment not Eighth Amendment violation)
Hamby v. Hammond, 821 F.3d 1085 (9th Cir. 2016) (difference of medical opinion does not establish deliberate indifference)