Black v. Department of State Hospitals

CourtDistrict Court, N.D. California
DecidedFebruary 6, 2023
Docket3:22-cv-05037
StatusUnknown

This text of Black v. Department of State Hospitals (Black v. Department of State Hospitals) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Black v. Department of State Hospitals, (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 SIVA D. BLACK, Case No. 22-cv-05037-JD

8 Plaintiff, ORDER RE SERVICE v. 9

10 DEPARTMENT OF STATE HOSPITALS, et al., 11 Defendants.

12 13 Plaintiff, a former patient at Napa State Hospital, filed a pro se civil rights complaint under 14 42 U.S.C. § 1983. In the Court’s initial screening order, plaintiff’s original and first amended 15 complaints were dismissed with leave to amend. Plaintiff has filed a second amended complaint 16 (SAC). The due process claims are dismissed with prejudice. The religious practices claims will 17 go forward. 18 DISCUSSION 19 STANDARD OF REVIEW 20 Federal courts must engage in a preliminary screening of cases in which prisoners seek 21 redress from a governmental entity or officer or employee of a governmental entity. 28 U.S.C. 22 § 1915A(a). In its review, the Court must identify any cognizable claims, and dismiss any claims 23 which are frivolous, malicious, fail to state a claim upon which relief may be granted, or seek 24 monetary relief from a defendant who is immune from such relief. Id. at 1915A(b)(1),(2). Pro se 25 pleadings are liberally construed. Balistreri v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 26 1990). 27 Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the 1 factual allegations, . . . a plaintiff’s obligation to provide the ‘grounds’ of his ‘entitle[ment] to 2 relief’ requires more than labels and conclusions, and a formulaic recitation of the elements of a 3 cause of action will not do. . . . Factual allegations must be enough to raise a right to relief above 4 the speculative level.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations 5 omitted). A complaint must proffer “enough facts to state a claim to relief that is plausible on its 6 face.” Id. at 570. The United States Supreme Court has explained the “plausible on its face” 7 standard of Twombly: “While legal conclusions can provide the framework of a complaint, they 8 must be supported by factual allegations. When there are well-pleaded factual allegations, a court 9 should assume their veracity and then determine whether they plausibly give rise to an entitlement 10 to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). 11 To state a claim under 42 U.S.C. § 1983, a plaintiff must allege that: (1) a right secured by 12 the Constitution or laws of the United States was violated, and (2) the alleged deprivation was 13 committed by a person acting under the color of state law. West v. Atkins, 487 U.S. 42, 48 (1988). 14 LEGAL CLAIMS 15 Plaintiff’s main claim is that he is being involuntary medicated in violation of his religious 16 beliefs. The SAC also appears to allege due process claims, in considerably less clear and 17 emphatic terms. In light of plaintiff’s pro se status, the Court will assume such claims have been 18 presented. 19 The Supreme Court has recognized a liberty interest in freedom from unwanted 20 antipsychotic drugs. Washington v. Harper, 494 U.S. 210, 221-22 (1990); United States v. Ruiz- 21 Gaxiola, 623 F.3d 684, 691 (9th Cir. 2010). For convicted inmates, or those awaiting trial, the 22 “liberty interest in avoiding unwanted medication must be defined in the context of the inmate’s 23 confinement.” United States v. Loughner, 672 F.3d 731, 745 (9th Cir. 2012) (quoting Harper, 494 24 U.S. at 222). If it is determined that an inmate is a danger to himself or others, and treatment in 25 his medical interest, the Due Process Clause allows the State to treat an inmate with serious mental 26 illness with antipsychotropic drugs against his will. See Harper, 494 U.S. at 227; Riggins v. 27 Nevada, 504 U.S. 127, 135 (1992). Such treatment requires a determination by a neutral factfinder 1 application. See Kulas v. Valdez, 159 F.3d 453, 455-56 (9th Cir. 1998); Harper, 494 U.S. at 233 2 (administration of antipsychotic drugs “cannot withstand challenge if there are no procedural 3 safeguards to ensure the prisoner's interests are taken into account.”). 4 Although a prisoner has the right to be present at and participate in a pretreatment hearing, 5 this requirement may be relaxed in an emergency situation where the prisoner poses an imminent 6 and serious danger to himself or others. See Kulas, 159 F.3d at 456; Loughner, 672 F.3d at 754. 7 A decision to forcibly medicate because of dangerousness need not meet any heightened standard 8 of proof in order to comport with due process. Loughner at 756. An inmate is not entitled to 9 counsel at an involuntary medication hearing. Id. at 756-57. 10 In California, the procedural requirements for involuntary medication of prisoners are 11 stated in Keyhea v. Rushen, 178 Cal.App.3d 526 (Cal. Ct. App. 1986). “A Keyhea order permits 12 the long-term involuntary medication of an inmate upon a court finding that the course of 13 involuntary medication is recommended and that the prisoner, as a result of mental disorder, is 14 gravely disabled and incompetent to refuse medication, or is a danger to himself or others.” Davis 15 v. Walker, 745 F.3d 1303, 1307 n.2 (9th Cir. 2014). 16 For plaintiff’s religious beliefs claim, Section 3 of the Religious Land Use and 17 Institutionalized Persons Act (“RLUIPA”) applies. “No government shall impose a substantial 18 burden on the religious exercise of a person residing in or confined to an institution, as defined in 19 section 1997 [which includes state prisons, state psychiatric hospitals, and local jails], even if the 20 burden results from a rule of general applicability, unless the government demonstrates that 21 imposition of the burden on that person (1) is in furtherance of a compelling governmental 22 interest; and (2) is the least restrictive means of furthering that compelling governmental interest.” 23 42 U.S.C. § 2000cc-1(a). The statute applies “in any case” in which “the substantial burden is 24 imposed in a program or activity that receives Federal financial assistance.” 42 U.S.C. § 2000cc- 25 1(b)(1). RLUIPA grants a private right of action: “A person may assert a violation of [RLUIPA] 26 as a claim or defense in a judicial proceeding and obtain appropriate relief against a government.” 27 42 U.S.C. § 2000cc-2(a); cf. § 2000bb-1(c). For purposes of this provision, “government” 1 other person acting under color of state law.” 42 U.S.C.

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Related

West v. Atkins
487 U.S. 42 (Supreme Court, 1988)
Washington v. Harper
494 U.S. 210 (Supreme Court, 1990)
Riggins v. Nevada
504 U.S. 127 (Supreme Court, 1992)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
United States v. Ruiz-Gaxiola
623 F.3d 684 (Ninth Circuit, 2010)
United States v. Loughner
672 F.3d 731 (Ninth Circuit, 2012)
Dawud Halisi Malik v. Neal Brown
16 F.3d 330 (Ninth Circuit, 1994)
Earnest Woods, II v. Tom Carey
684 F.3d 934 (Ninth Circuit, 2012)
Shakur v. Schriro
514 F.3d 878 (Ninth Circuit, 2008)
Keyhea v. Rushen
178 Cal. App. 3d 526 (California Court of Appeal, 1986)
Kennard Davis v. James Walker
745 F.3d 1303 (Ninth Circuit, 2014)
United States v. Iwuala
789 F.3d 1 (First Circuit, 2015)
Kulas v. Valdez
159 F.3d 453 (Ninth Circuit, 1998)
Wyatt v. Terhune
315 F.3d 1108 (Ninth Circuit, 2003)

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Black v. Department of State Hospitals, Counsel Stack Legal Research, https://law.counselstack.com/opinion/black-v-department-of-state-hospitals-cand-2023.