(PC) Crayon v. Hill
2:13-cv-00350
E.D. Cal.May 9, 2014Background
- Crayon, a state prisoner, proceeds in a 42 U.S.C. § 1983 action in the Eastern District of California.
- The court considers motions to dismiss filed by Stocker, Hill, and Wang (12(b)(6)) with amended pleadings.
- Plaintiff alleges Wang gave wrong medication in retaliation for grievances; Stocker allegedly rejected grievances; Hill allegedly allowed unsanitary conditions and improper bunk placement and retaliated.
- Allegations include that Wang’s action caused illness; plaintiff sought toxicology and neurology reports; Stocker allegedly covered up by dismissing grievances.
- The court analyzes due process concerns regarding grievance processing and possible conspiratorial cover-up, and grants leave to amend certain claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Wang’s alleged wrong medication support a retaliation claim? | Wang gave wrong meds shortly after grievances, showing retaliatory motive. | Exhibits negate wrong medication and no retaliatory intent; lack of evidence of personal participation. | Claim survives, defendants’ dismissal denied; plausible retaliation and deliberate indifference shown. |
| Does Wang’s conduct support an Eighth Amendment deliberate-indifference claim? | Wrong medication and retaliation violated medical care. | No adequate factual basis of deliberate indifference or causal link. | Claim survives; deliberate indifference plausibly alleged and motive shown. |
| Are Hill’s links to unsanitary conditions, bunk placement, and retaliation displayed sufficiently to proceed? | Hill knew of unsanitary conditions and improper bunk, retaliating against staff complaints. | Plaintiff failed to show Hill’s knowledge or direct involvement; claims are speculative. | Dismissed with leave to amend for unsanitary conditions and top-bunk claim; retaliation claim dismissed with leave to amend. |
| Is Stocker liable for a due-process violation by allegedly failing to process grievances? | Stocker’s denial/retaliation against grievances violates access to courts. | No due-process right to a specific grievance process; claim should be dismissed. | Dismissed without leave to amend. |
| Is there a viable conspiracy claim to cover up Wang’s misconduct involving Hill or Stocker? | Hill and Stocker participated in cover-up by ignoring/grievance handling. | Premature or meritless without ripe injury; no actionable cover-up yet. | Dismissed as to Hill and Stocker; prematurity and lack of ripe injury barred. |
Key Cases Cited
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity analysis)
- Twombly, 550 U.S. 544 (2007) (pleading standard: must plead plausible claims)
- Iqbal, 556 U.S. 662 (2009) (rejects bare conclusory allegations; requires facial plausibility)
- Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard; objective and subjective components)
- Estelle v. Gamble, 429 U.S. 97 (1976) (prison conditions and medical care; deliberate indifference)
- Hishon v. King & Spaulding, 467 U.S. 69 (1984) (stringent pleading standards for federal claims)
- Rizzo v. Dawson, 778 F.2d 527 (9th Cir. 1985) (retaliation claims require more than mere timing)
- Karim-Panahi v. Los Angeles Police Dept., 839 F.2d 621 (9th Cir. 1988) (prematurity of cover-up claims pending underlying claims)
- Morales v. City of Los Angeles, 214 F.3d 1151 (9th Cir. 2000) (ripeness of access-to-courts claims)
- Delew v. Wagner, 143 F.3d 1219 (9th Cir. 1998) (prematurity of cover-up allegations)
- Gibson v. County of Washoe, 290 F.3d 1175 (9th Cir. 2002) (deliberate indifference requires actual perception of risk)
- Toguchi v. Chung, 391 F.3d 1051 (9th Cir. 2004) (medical care deliberate indifference standard)