(PC)Huskey v. Ahlin, 1:12-cv-00569

Background

Kenneth R. Huskey, a civil detainee at Coalinga State Hospital, sued under 42 U.S.C. § 1983 (and later added an ADA claim) alleging defendants failed to provide medically-necessary all-cotton clothing for his contact dermatitis.
Earlier proceedings: court previously dismissed claims about all-cotton t‑shirts and ill‑fitting clothing with prejudice, but allowed amendment to clarify claims about other all‑cotton garments (e.g., pants).
Huskey alleges Dr. Colbert ordered all‑cotton pants (Nov. 2010; medical record reference Mar. 16, 2011) but clothing-room supervisor Craig and administrators Ahlin, Brown, Young failed to ensure delivery, leading to persistent skin problems.
Plaintiff exhausted administrative remedies and pursued state mandamus proceedings, which were denied on appeal; family‑sent clothing was allegedly confiscated by hospital police.
Court reviewed amended complaint and exhibits and found (1) deficient factual specificity tying defendants’ conduct to a constitutional violation, (2) medical records did not support allegations of urgent, severe open sores caused by polyester exposure, and (3) defendants were not directly responsible for medical treatment decisions.
Court denied appointment of counsel (no exceptional circumstances / low likelihood of success) and recommended dismissal with prejudice for failure to state a claim (§ 1983 and ADA). No further leave to amend.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants violated substantive due process by denying medically‑necessary all‑cotton pants	Huskey: Dr. Colbert ordered cotton pants; defendants failed to provide them, causing rash, sores, emotional distress	Defendants: not responsible for medical care decisions; medical records do not show urgent need or causal link to constitutional violation	Dismissed — plaintiff failed to plead specific causal connection or show defendants’ conduct rose to gross‑negligence/conscious indifference under Youngberg standard
Adequacy of amended complaint under Rule 8 / Iqbal-Twombly plausibility standard	Huskey: amendments clarify prior deficiencies and demonstrate ongoing harm from synthetic clothing	Defendants: allegations remain vague, repeat previously dismissed t‑shirt/fit claims, and lack factual detail tying each defendant to constitutional harm	Dismissed — pleadings are conclusory and not plausibly connected to each defendant; prior deficiencies not cured
Claim under ADA for denial of reasonable accommodation	Huskey: failure to provide cotton pants constitutes disability discrimination / denial of accommodation	Defendants: alleged harms concern medical treatment, not discrimination actionable under ADA	Dismissed — ADA does not provide a remedy for inadequate medical treatment
Request for appointment of counsel	Huskey: needs counsel to prosecute claims	Defendants: N/A (court evaluates)	Denied — no exceptional circumstances; low likelihood of success and plaintiff able to articulate claims sufficiently

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (conclusory allegations insufficient under pleading standard)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility requirement for complaints)
Youngberg v. Romeo, 457 U.S. 307 (civil detainees’ substantive‑due‑process standard; professional‑judgment/gross‑negligence framework)
Palmer v. Valdez, 560 F.3d 965 (no constitutional right to appointed counsel in civil rights actions; exceptional‑circumstances test)
Wilborn v. Escalderon, 789 F.2d 1328 (factors for appointment of counsel in pro se civil cases)
Ammons v. Washington Dep’t of Soc. & Health Servs., 648 F.3d 1020 (Youngberg standard equated to gross negligence)
Ramirez v. Galaza, 334 F.3d 850 (dissatisfaction with administrative appeals does not state a § 1983 claim)
Simmons v. Navajo Cnty., 609 F.3d 1011 (ADA does not cover claims that are essentially inadequate medical treatment)
Lemire v. California Dep’t of Corr. and Rehab., 726 F.3d 1062 (causal‑link requirement for § 1983 claims)
Starr v. Baca, 652 F.3d 1202 (supervisor liability and need to plead factual connection)