Adams v. Lanum

CourtDistrict Court, W.D. Washington
DecidedFebruary 8, 2024
Docket3:24-cv-05034
StatusUnknown

This text of Adams v. Lanum (Adams v. Lanum) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adams v. Lanum, (W.D. Wash. 2024).

Opinion

1 2 3 4

5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 RYAN SCOTT ADAMS, CASE NO. 3:24-CV-5034-KKE-DWC 11 Plaintiff, v. ORDER DECLINING TO SERVE 12 COMPLAINT BRUCE LANUM, et al., 13 Defendants. 14

15 Plaintiff Ryan S. Adams, proceeding pro se and in forma pauperis, filed this civil rights 16 action under 42 U.S.C. § 1983. Having reviewed and screened Plaintiff’s complaint under 28 17 U.S.C. §1915A, the Court declines to serve the complaint but provides Plaintiff leave to file an 18 amended pleading by March 10, 2024, to cure the deficiencies identified herein. 19 I. Background 20 On March 12, 2023, Plaintiff injured his hand in an altercation with his former cellmate. 21 Dkt. 7, at 4. Since that day, Plaintiff has sought treatment for his hand, which he believes to be 22 broken and healing badly. Id. at 4–6. Although the precise order of events outlined in the 23 complaint is difficult to decipher, Plaintiff discusses the treatment he received at two different 24 1 corrections facilities, Clallam Bay Corrections Center (“CBCC”) and Washington Corrections 2 Center (“WCC”). Id. It appears Plaintiff was satisfied with—or at least he does not complain 3 about—the medical treatment he received at CBCC. Id. at 5. Instead, Plaintiff’s real concern is 4 with the treatment he received after he was transferred to WCC in September 2023. Id.

5 From the time he arrived at WCC, Plaintiff has been given only Tylenol or Tylenol 6 equivalents to manage his pain. Id. He says this care is worse than the treatment he received at 7 CBCC, which included, among other things, ace bandages. Id. During his time at WCC, Plaintiff 8 has discussed potential surgeries for his hand with the medical staff, but these discussions have 9 not resulted in a concrete treatment plan. Id. Plaintiff identifies Bruce Lanum as the medical staff 10 person who prescribed inadequate pain medication and Adam Clarino as the individual who 11 delayed and/or failed to follow up on a possible surgery. Id. Plaintiff explains that the inadequate 12 pain management and delays in treatment at WCC have aggravated his injuries and caused him 13 unnecessary suffering. Id. Plaintiff filed several grievances and two “tort claims” about the 14 subpar treatment he continues to receive at WCC. Id. at 5, 11.

15 Separate from the grievances Plaintiff submitted about his hand, he complains that other 16 grievances have been repeatedly mishandled by Lieutenant Tony Donnington, who is a hearings 17 officer at WCC. Id. 6–7, 12. Plaintiff claims he suffered emotionally and psychologically from 18 the mismanagement of his grievances. Id. at 7. 19 Plaintiff organizes his factual allegations into two counts. Count I concerns the medical 20 treatment Plaintiff received at WCC and is styled as a claim for “medical negligence” and 21 “medical malpractice” under the Americans with Disabilities Act (“ADA”), the Due Process 22 Clause, and the Eighth and Fourteenth Amendments to the United States Constitution. Id. at 4. 23 Count II involves Lt. Donnington’s alleged mishandling of Plaintiff’s grievances and is styled as

24 1 a claim for “procedural civil violations” under the Due Process Clause and Equal Protection 2 Clause. Id. at 6. Plaintiff seeks compensatory damages on both counts. Id. at 9. 3 II. Discussion 4 Under the Prison Litigation Reform Act of 1995, the Court is required to screen

5 complaints brought by prisoners seeking relief against a governmental entity or officer or 6 employee of a governmental entity. 28 U.S.C. § 1915A(a). The Court must “dismiss the 7 complaint, or any portion of the complaint, if the complaint: (1) is frivolous, malicious, or fails to 8 state a claim upon which relief may be granted; or (2) seeks monetary relief from a defendant 9 who is immune from such relief.” Id. at (b); 28 U.S.C. § 1915(e)(2); see Barren v. Harrington, 10 152 F.3d 1193 (9th Cir. 1998). 11 The Court is required to liberally construe pro se documents. Estelle v. Gamble, 429 U.S. 12 97, 106 (1976). However, the pleadings must raise the right to relief beyond the speculative level 13 and must provide “more than labels and conclusions, and a formulaic recitation of the elements 14 of a cause of action will not do.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citing

15 Papasan v. Allain, 478 U.S. 265, 286 (1986)). 16 A. ADA Claim 17 The Court will address Plaintiff’s ADA claim before turning to his constitutional claims 18 brought pursuant to 42 U.S.C. § 1983. 19 Individuals housed in corrections facilities are protected by Title II of the ADA, which 20 prohibits “public entities” from engaging in disability-based discrimination or excluding 21 individuals from the benefits of its services or programs “by reason of” their disability. 42 U.S.C. 22 § 12132; O’Guinn v. Lovelock Corr. Ctr., 502 F.3d 1056, 1060 (9th Cir. 2007). To state a claim 23 under Title II of the ADA, a plaintiff must plausibly allege the following:

24 1 (1) he is an individual with a disability; (2) he is otherwise qualified to participate in or receive the benefit of some public entity’s services, programs, or activities; 2 (3) he was either excluded from participation in or denied the benefits of the public entity's services, programs, or activities, or was otherwise discriminated against by 3 the public entity; and (4) such exclusion, denial of benefits, or discrimination was by reason of his disability. 4 McGary v. City of Portland, 386 F.3d 1259, 1265 (9th Cir. 2004) (cleaned up). 5 For the following analysis, the Court will assume Plaintiff’s injured hand qualifies as a 6 “disability” protected by the ADA. Cf. Sanders v. Arneson Prod., Inc., 91 F.3d 1351, 1354 (9th 7 Cir. 1996) (a temporary impairment lasting 4-months with no residual effects was not a disability 8 within the meaning of the ADA). Even so, Plaintiff’s ADA claim is deficient because (1) he does 9 not identify a proper defendant for his claim and (2) he fails to allege he was denied the benefits 10 of a public entity’s services or programs by reason of—or because of—his disability. 11 First, the proper defendant for a Title II ADA claim is a “public entity,” which is defined 12 as “any State or local government [and] any department, agency, special purpose district, or 13 other instrumentality of a State or States or local government.” 42 U.S.C. § 12131(1). This 14 language is broad enough to encompass corrections facilities. Armstrong v. Wilson, 124 F.3d 15 1019, 1023 (9th Cir. 1997). However, it does not encompass the individuals employed by those 16 facilities. Because Plaintiff only names WCC employees as defendants in his action and not the 17 corrections facility itself, he has not named a proper defendant on his ADA claim. 18 Second, the ADA prohibits public entities from excluding individuals from the benefits 19 of its services or programs “by reason of” that individual’s disability. 42 U.S.C. § 12132.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Griffin v. School Bd. of Prince Edward Cty.
377 U.S. 218 (Supreme Court, 1964)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Meachum v. Fano
427 U.S. 215 (Supreme Court, 1976)
United States v. Pomponio
429 U.S. 10 (Supreme Court, 1976)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
City of Cleburne v. Cleburne Living Center, Inc.
473 U.S. 432 (Supreme Court, 1985)
Papasan v. Allain
478 U.S. 265 (Supreme Court, 1986)
Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Hudson v. McMillian
503 U.S. 1 (Supreme Court, 1992)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Sandin v. Conner
515 U.S. 472 (Supreme Court, 1995)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jeremy Crozier v. Adam Endel
447 F. App'x 859 (Ninth Circuit, 2011)
John C. McGuckin v. Dr. Smith John C. Medlen, Dr.
974 F.2d 1050 (Ninth Circuit, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
Adams v. Lanum, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adams-v-lanum-wawd-2024.