Redwine v. Branch, M.D., 3:15-cv-03109

Plaintiff Raymond Allen Redwine, a state inmate, filed a pro se suit labeled habeas but alleging denial of medical care; court reclassified it as a § 1983 civil rights action.
He alleges denial of treatment for severe epicondylitis (tennis elbow) and ongoing, severe pain, including a denied request to see a specialist.
Complaint named only the facility warden (M.E. Spearman) and attached ~170 pages of exhibits but contained few factual allegations tying actions to specific defendants.
The case was screened under 28 U.S.C. § 1915A to determine whether the complaint states a cognizable claim for relief.
The court applied Eighth Amendment deliberate-indifference standards and related Ninth Circuit and Supreme Court precedent to evaluate the sufficiency of the pleading.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint states an Eighth Amendment deliberate-indifference claim for denial of medical care	Redwine alleges he suffers severe pain from epicondylitis and was denied specialist care and treatment	(Implicit) Only the warden is named; complaint lacks specific allegations tying individuals to denial of care; exhibits alone are insufficient	Complaint dismissed for failure to state a claim but dismissal is without prejudice; plaintiff granted leave to amend to identify specific defendants and factual acts
Whether plaintiff pleaded sufficient facts to proceed in forma pauperis screening under § 1915A	Plaintiff relies on exhibits and general allegations of denial of care	Court requires specific factual allegations showing who denied care, what was denied, what care was provided, and why it was constitutionally inadequate	Court ordered reclassification as civil rights action and dismissal with leave to file a First Amended Complaint containing clear, concise allegations against each defendant

Hebbe v. Pliler, 627 F.3d 338 (9th Cir. 2010) (pro se pleadings must be liberally construed)
Balistreri v. Pacifica Police Dep’t, 901 F.2d 696 (9th Cir. 1990) (pleading standards for pro se litigants)
West v. Atkins, 487 U.S. 42 (1988) (elements of § 1983 action)
Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates the Eighth Amendment)
McGuckin v. Smith, 974 F.2d 1050 (9th Cir. 1992) (definition of serious medical need and analysis of deliberate indifference)
Farmer v. Brennan, 511 U.S. 825 (1994) (official must know and disregard a substantial risk of serious harm)
Gibson v. County of Washoe, 290 F.3d 1175 (9th Cir. 2002) (officials not liable where they were not actually aware of risk)
Lacey v. Maricopa County, 693 F.3d 896 (9th Cir. 2012) (amended complaint supersedes prior pleadings; claims not repled may be waived)