Quintero v. Aranas, 3:17-cv-00066-MMD-CLB

Plaintiff John Quintero, an NDOC inmate, proceeded on two claims in his third amended complaint: Count V (Fourteenth Amendment equal protection) against Chaplains Calderin and Burse and Defendant Wickham; and Count VI (Eighth Amendment conditions of confinement/deliberate indifference) against Baca, Wickham, and Warden Olsen.
Count V alleges the Religious Review Team (RRT) accommodated other faiths with outdoor prayer space but denied comparable outdoor worship opportunities to Quintero (a Catholic).
Count VI alleges unsafe conditions due to inadequate guard-to-inmate staffing, and Quintero contends the Stickney class-action staffing injunction supports his claim.
Defendants moved for summary judgment arguing, inter alia, that Quintero had equal access to religious space, lacked proof of discriminatory intent, was not harmed by staffing levels, Stickney’s injunction did not apply to his unit, and they are entitled to qualified immunity.
The magistrate judge recommended denial of summary judgment as to Count V (equal protection) because Defendants did not meet their initial burden and disputed factual issues remain; recommended summary judgment for Defendants as to Count VI because Stickney’s remedies applied only to Units 1–3, Quintero was housed in Unit 10A, he suffered no injury, and there is no evidence Defendants were aware of a serious risk. The report also recommends dismissal of Baca and Olsen from the action.

Issue	Quintero's Argument	Defendants' Argument	Held
Equal Protection (Count V) — religious-access parity	Quintero: RRT gave outdoor prayer accommodations to other faiths but denied comparable outdoor worship to him (Catholic).	Defendants: Quintero had the same access to chapel and could pray individually or with others; no purposeful discrimination; no showing under Turner factors.	Summary judgment denied as to Count V; triable issues remain and qualified immunity is not appropriate.
Conditions of Confinement (Count VI) — staffing/deliberate indifference	Quintero: Understaffing at NNCC creates a substantial risk to safety; Stickney injunction supports his claim.	Defendants: Stickney staffing injunction applied only to Units 1–3; Quintero was in Unit 10A, suffered no injury, and Defendants lacked knowledge of a serious risk.	Summary judgment granted for Defendants as to Count VI; Baca and Olsen recommended for dismissal.

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
Anderson v. Liberty Lobby, 477 U.S. 242 (genuine-dispute standard at summary judgment)
Turner v. Safley, 482 U.S. 78 (reasonableness test for prison regulations affecting constitutional rights)
Cruz v. Beto, 405 U.S. 319 (prisoners entitled to reasonable opportunity to pursue faith)
Shakur v. Schriro, 514 F.3d 878 (applies Turner to prison religious equal protection claims)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for inmate safety)
Rhodes v. Chapman, 452 U.S. 337 (Eighth Amendment conditions-of-confinement principles)
Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework)
Ashcroft v. al-Kidd, 563 U.S. 731 (clearly-established-law standard for qualified immunity)
Frost v. Agnos, 152 F.3d 1124 (mere negligence insufficient for constitutional liability)
Serrano v. Francis, 345 F.3d 1071 (clarifies analysis of clearly established rights)