(PC) Richardson v. Corizon Health Care
1:17-cv-00684
E.D. Cal.Feb 22, 2018Background
- Pro se plaintiff Jared Richardson (also Janette Ryukuza Murakami), a pretrial detainee at Fresno County Jail, sued Corizon and several medical staff under 42 U.S.C. § 1983 for denial of gender‑affirming care and inadequate mental health treatment.
- Plaintiff sought hormone replacement therapy and psychiatric care for gender dysphoria, filed multiple medical requests and grievances between 2015–2017, and reported self‑harm attempts (including cutting and an attempted self‑orchiectomy).
- Grievances indicated Corizon policy prevented initiation of hormone therapy in custody; Plaintiff received psychiatric contact but alleged treatment was inadequate and requests were ignored or denied.
- Specific defendants: Corizon Health; Mike Stribling, LMFT; Edward Crossman, LMFT (MH Supervisor); Harold R. Turl, Ph.D.; and May Vang, Psychiatric RN.
- The magistrate judge screened the first amended complaint under 28 U.S.C. § 1915A and found cognizable Fourteenth Amendment inadequate‑medical‑care claims only against Crossman and Vang; recommended dismissal of all other claims and defendants for failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pretrial detainee inadequate‑medical‑care claim stated against Crossman and Vang | Richardson alleges Crossman and Vang failed to take reasonable steps to provide needed mental health/gender‑affirming care, causing self‑harm | Defendants implicitly argue lack of deliberate indifference or reasonable steps were taken; screening evaluates plausibility | Court held claim cognizable against Crossman and Vang under Fourteenth Amendment (plausibly alleged failure to take reasonable steps resulting in harm) |
| Whether Corizon and Turl are liable based on policy denying initiation of hormone therapy | Richardson argues the policy prevented care and caused harm | Corizon/Turl contend policy limited initiation but psychiatric treatment occurred and no plausible pre‑detention diagnosis or medical necessity was pleaded | Court dismissed Corizon and Turl—plaintiff failed to plausibly allege pre‑detention diagnosis or medical necessity tied to policy liability |
| Whether Stribling is liable for missed/incorrect appointment and saying he was unqualified | Richardson asserts Stribling’s conduct contributed to lack of care | Stribling’s error was isolated and did not show awareness of a high risk of harm or causation | Court dismissed claims against Stribling for failure to allege that a reasonable medical provider in his position appreciated a high risk of harm or caused plaintiff’s injuries |
| Whether claims based on grievance processing are actionable | Richardson alleges harms from deficient grievance handling and adverse grievance outcomes | Defendants assert grievance process does not create protected liberty interest actionable under § 1983 | Court dismissed grievance‑related claims (no protected liberty interest in grievance outcomes) |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard requires more than conclusory statements)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (governing Fourteenth Amendment standard for certain pretrial detainee claims)
- Castro v. County of Los Angeles, 833 F.3d 1060 (9th Cir. 2016) (extended Kingsley reasoning to some pretrial detainee claims)
- Clouthier v. County of Contra Costa, 591 F.3d 1232 (9th Cir.) (earlier Ninth Circuit discussion of pretrial detainee medical‑care standard)
- Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) (no constitutional right to a specific grievance outcome)
- Mann v. Adams, 855 F.2d 639 (9th Cir.) (inmate grievance procedures do not create a liberty interest)