(PC)Taylor v. Arakaki, 1:14-cv-00479

Plaintiff Latroy Taylor, a state prisoner proceeding pro se and in forma pauperis, filed a § 1983 claim arising from dental treatment at California State Prison–Corcoran in April–June 2013.
Defendants are prison medical/dental staff: Drs. Lance Arakaki, Andrew Elms, D. Beregouskya, Joseph McQuirter, Mel J. Carpenter, and J. Rodriguez.
Relevant events: difficulty achieving local anesthesia during an April 11 procedure (Arakaki); April 18 injection by Elms allegedly struck a nerve causing severe pain; subsequent complaints of jaw locking, limited opening, popping, numbness, and pain.
Various clinicians evaluated Plaintiff, diagnosed trismus/tetanus at times, ordered x‑rays, Boost Plus, and referral to an oral surgeon; some prescribed pain medication but Plaintiff sought stronger medication.
Plaintiff alleges defendants ignored pain, refused adequate medication, and McQuirter falsified records; he seeks damages and declaratory relief for Eighth Amendment deliberate indifference.
Court screened the third amended complaint, found only allegations of negligence or disagreement with treatment, and dismissed the action for failure to state a § 1983 claim with prejudice (no further leave to amend).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dental/medical conduct amounted to Eighth Amendment deliberate indifference	Taylor contends injection/diagnoses and refusal to provide stronger pain meds amounted to cruel and unusual punishment	Defendants provided care, diagnosed and treated, and differences reflect medical judgment not deliberate indifference	Dismissed: allegations show at most negligence or disagreement with treatment, not deliberate indifference
Whether alleged nerve injury from injection states constitutional claim	Taylor asserts Elms struck a nerve causing prolonged severe pain	Elms' conduct was at most negligent medical treatment	Dismissed: negligent conduct insufficient for § 1983 claim
Whether denial/refusal to prescribe stronger pain meds violated Eighth Amendment	Taylor alleges Arakaki, Rodriguez, Beregouskya refused adequate pain relief	Records show some providers prescribed meds, evaluated condition, and made treatment choices	Dismissed: mere disagreement over pain management does not state claim
Whether falsification of records by McQuirter supports claim	Taylor alleges McQuirter falsified records to deny surgery	Court notes exhibits and prior allegations show McQuirter examined Plaintiff and documented objective findings; Plaintiff previously failed to cure defects	Dismissed: Plaintiff failed to cure pleading deficiencies; no viable claim shown

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain factual content sufficient for plausibility)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Estelle v. Gamble, 429 U.S. 97 (1976) (medical malpractice and negligence do not alone constitute Eighth Amendment violations)
Jett v. Penner, 439 F.3d 1091 (9th Cir. 2006) (two‑part deliberate indifference test)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference requires knowledge of and disregard of an excessive risk)
Broughton v. Cutter Laboratories, 622 F.2d 458 (9th Cir. 1980) (indifference must be substantial; negligence insufficient)
Sanchez v. Vild, 891 F.2d 240 (9th Cir. 1989) (disagreement with diagnosis/treatment not an Eighth Amendment violation)
Wood v. Housewright, 900 F.2d 1332 (9th Cir. 1990) (even gross negligence insufficient for deliberate indifference)
Simmons v. Navajo County Ariz., 609 F.3d 1011 (9th Cir. 2010) (deliberate indifference is a high legal standard)
Moss v. United States Secret Service, 572 F.3d 962 (9th Cir. 2009) (pleading must permit reasonable inference of liability)
Lopez v. Smith, 203 F.3d 1122 (9th Cir. 2000) (standards on granting leave to amend for pro se plaintiffs)