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