Scott v. NaphCare, 3:19-cv-00347

Background

Plaintiff James Edward Scott, a pretrial detainee, sued under 42 U.S.C. § 1983 alleging inadequate medical care and retaliation arising from treatment at Clark County Detention Center (CCDC).
Dr. Williamson prescribed lisinopril for hypertension and escalated the dose to 40 mg/day over several weeks after ordering—but apparently not obtaining—baseline renal labs.
On April 11–18, 2018 UMC treated Scott and documented “acute renal failure superimposed on stage 4 chronic kidney disease.” A nephrologist at UMC noted lisinopril could affect kidney function.
Dr. Feely (nephrologist) saw Scott after UMC: initially noted the presentation leaned toward AKI but later assessed CKD stage IV and ordered a renal biopsy showing severe chronic changes; she managed medications thereafter.
Defendants’ expert opined the biopsy showed long‑standing chronic kidney disease and that care met the standard; Scott points to NIH materials and later prison physician comments asserting lisinopril risks and racial differences in effectiveness.
Procedurally: Magistrate Judge Denney issued three R&Rs—granting summary judgment for Drs. Williamson and Feely (ECF No. 112), granting for Costello (ECF No. 113), and denying for Officer Franklin (ECF No. 114). The district court adopted the R&Rs as to Feely, Costello, and Franklin but denied summary judgment as to Williamson because a triable dispute exists over whether Scott suffered an acute injury caused or exacerbated by lisinopril.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Liability of Dr. Williamson for inadequate medical care (pretrial detainee)	Williamson prescribed and escalated lisinopril without baseline renal function, knew risks for Black patients and those with renal impairment, and caused/exacerbated kidney injury	Care was proper; biopsy and expert show chronic, long‑standing CKD not caused by Williamson; no causal link	District court denied summary judgment for Williamson — genuine dispute on acute vs chronic injury and objective unreasonableness of prescribing lisinopril exists
Liability of Dr. Feely for inadequate care	Feely’s post‑hospital nephrology management (including medication choices) contributed to injury	Feely treated after UMC diagnosis and her care did not cause the injury; management reasonable	Court adopted R&R and granted summary judgment for Feely (no causal liability shown)
Costello — exhaustion of administrative remedies	Grievance procedure was unavailable or not effectively communicated; plaintiff filed some grievances	Plaintiff did not exhaust available grievance remedies as to Costello’s conduct	Court adopted R&R and granted summary judgment for Costello for failure to exhaust
Franklin — retaliation/denial of medication and qualified immunity	Franklin retaliated after plaintiff requested to file a grievance, prevented plaintiff from attending pill call causing missed meds and damage; plaintiff exhausted remedies	Franklin asserted legitimate penological reasons and qualified immunity	Court adopted R&R and denied summary judgment for Franklin — genuine disputes and qualified immunity not established

Key Cases Cited

Gordon v. County of Orange, 888 F.3d 1118 (9th Cir. 2018) (sets the objective deliberate‑indifference standard for pretrial detainee medical claims)
Russell v. Lumitan, 31 F.4th 729 (9th Cir.) (explains that conflicting reasonable interpretations of evidence can preclude summary judgment and supports jury resolution of deliberate‑indifference disputes)
Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden‑shifting framework)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine‑issue and materiality standards for summary judgment)
Thomas v. Arn, 474 U.S. 140 (standards for district court review of unobjected‑to magistrate judge recommendations)
Castro v. County of Los Angeles, 833 F.3d 1060 (9th Cir. 2016) (precursor Ninth Circuit authority regarding standards for pretrial detainee claims)