Medina v. Dr. Claire Williams, MD, 5:10-cv-03610

Plaintiff Francisco J. Medina, a former Pelican Bay inmate, sued under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference for denial/delay of diagnostics, specialist referrals, injections, and certain pain medications.
Earlier summary judgment resolved several claims: the court denied summary judgment for Dr. Claire Williams (treating physician) on refusal to order a CT discogram, administer an epidural, refer to an orthopedic spine surgeon, and for discontinuing/delaying pain medication; other defendants were dismissed.
This decision addresses whether Dr. Michael Sayre (Chief Medical Officer) is liable for the remaining treatment decisions. Sayre was not the treating physician and did not personally examine Medina.
Sayre’s role: review of medical appeals, evaluation of complex chronic cases, and approval/denial of appeals after the appeals office’s preliminary review; he does not make day-to-day treatment decisions.
Medina filed three health-care appeals (2009–2011) challenging Williams’ care; Sayre approved some accommodations (bottom bunk, cane) and denied or partially denied requests for certain medications, CT scan, specialist referrals, and epidural injections after reviewing the record.
Medina alleged Sayre knew of and participated in inadequate treatment; court limited evidence to Sayre’s review signatures and appeal decisions without first-hand exam or objective proof that treatment was medically unacceptable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sayre was deliberately indifferent to a serious medical need by authorizing/participating in inadequate treatment (denials of CT, epidural, referrals, meds)	Sayre reviewed and signed appeal denials/approvals and therefore knew of Medina’s chronic, debilitating pain and maintained an inadequate treatment course	Sayre had limited, supervisory/appeals-review role, did not examine Medina, and his reviews fell within a range of reasonable medical judgment	No. Court held no triable issue of deliberate indifference; difference of opinion and appeal-review alone insufficient without objective evidence that treatment was medically unacceptable
Whether Sayre is liable as a supervisor (acquiescence or participation)	Sayre supervised medical care and signed off on decisions, so he participated/acquiesced in constitutional deprivation	Supervisor liability requires participation, direction, or knowledge with failure to act and a culpable state of mind; respondeat superior is insufficient	No. Court held no supervisor liability because requisite subjective state of mind not shown
Qualified immunity for Sayre	Plaintiff: not applicable because conduct was deliberate indifference	Sayre: asserted qualified immunity but court did not reach issue because it found no constitutional violation	Not reached (court resolved case on lack of deliberate indifference)

Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment claim for deliberate indifference to serious medical need)
Farmer v. Brennan, 511 U.S. 825 (subjective knowledge and deliberate indifference standard)
Snow v. McDaniel, 681 F.3d 978 (Ninth Circuit deliberate indifference framework)
Toguchi v. Chung, 391 F.3d 1051 (medical judgment vs. deliberate indifference; plaintiff must show treatment was medically unacceptable)
McGuckin v. Smith, 974 F.2d 1050 (definition of "serious medical need")
Jett v. Penner, 439 F.3d 1091 (presumption that reviewing official aware of inmate’s medical file)
Sanchez v. Vild, 891 F.2d 240 (difference of medical opinion insufficient for deliberate indifference)
Taylor v. List, 880 F.2d 1040 (no respondeat superior liability under § 1983)
Edgerly v. City and County of San Francisco, 599 F.3d 946 (supervisor liability requires acquiescence plus requisite state of mind)
Jackson v. McIntosh, 90 F.3d 330 (standard for when treatment choice can be deliberate indifference)
Ortiz v. City of Imperial, 884 F.2d 1312 (reversing where medical staff knowingly disregarded clear complications)