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(PC-G) Singleton, Sr. v. Biter
1:12-cv-00043
E.D. Cal.
May 20, 2014
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Background

  • Plaintiff Lamar Singleton is a state prisoner proceeding in forma pauperis and filed this civil rights action on January 9, 2012, against Biter and Lopez for Eighth Amendment violations.
  • Defendants’ November 21, 2013 motion to dismiss based on exhaustion was converted to a motion for summary judgment; the court awaits Plaintiff’s position on exhaustion discovery.
  • On May 7 and May 9, 2014, Plaintiff filed motions for emergency medical treatment, construed as requests for injunctive relief.
  • The requested relief concerns medical treatment at Mule Creek State Prison and issues at Kern Valley State Prison; the court notes it cannot grant relief over non-parties or unrelated facilities.
  • The court recommends denying Plaintiff’s motions for injunctive relief for lack of jurisdiction and absence of a case/controversy.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the court has jurisdiction to grant the requested injunctive relief. Singleton seeks medical relief and broader actions at Mule Creek. Court lacks jurisdiction over non-parties and unrelated facilities; relief not tied to Kern Valley events. Denied; no jurisdiction to grant relief unrelated to this action.
Whether the relief sought is properly limited to the Kern Valley actions and constitutes a proper narrowly drawn remedy. Relief should address the asserted Arsenic issues at Kern Valley. Relief sought is not narrowly drawn and not justified by case/controversy. Denied for not meeting case/controversy requirement and narrow tailoring.

Key Cases Cited

  • Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (U.S. 2008) (preliminary injunction requires a showing of standing and likelihood of success)
  • Summers v. Earth Island Institute, 555 U.S. 488 (U.S. 2009) (standing and imminence requirements for injunctive relief)
  • Mayfield v. United States, 599 F.3d 964 (9th Cir. 2010) (standing and imminence requirements for injunctive relief in 9th Circuit)
  • City of Los Angeles v. Lyons, 461 U.S. 95 (U.S. 1983) (actual case or controversy requirement for injunctive relief)
  • Valley Forge Christian College v. Americans United for Separation of Church and State, Inc., 454 U.S. 464 (U.S. 1982) (limits on prospective relief absent a live controversy)
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Case Details

Case Name: (PC-G) Singleton, Sr. v. Biter
Court Name: District Court, E.D. California
Date Published: May 20, 2014
Citation: 1:12-cv-00043
Docket Number: 1:12-cv-00043
Court Abbreviation: E.D. Cal.