Figueroa v. Sierra

CourtDistrict Court, D. Connecticut
DecidedJanuary 26, 2024
Docket3:23-cv-01625
StatusUnknown

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

Bluebook
Figueroa v. Sierra, (D. Conn. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

: JOSE FIGUEROA, : Plaintiff, : : v. : No. 3:23-cv-1625 (VAB) : CORRECTIONAL OFFICER : SIERRA, : Defendant. :

INITIAL REVIEW ORDER

Jose Figueroa, a pro se plaintiff, and who was formerly incarcerated, has filed a Complaint under 42 U.S.C. § 1983. He names Correctional Officer Sierra as the only Defendant. Mr. Figueroa alleges deliberate indifference to a serious medical need by Officer Sierra, who allegedly failed to immediately summon medical assistance. He seeks damages only. The Prison Litigation Reform Act requires that federal courts review complaints brought by prisoners seeking relief against a government entity or officer or employee of a government entity. 28 U.S.C. § 1915A(a). Upon review, the Court must dismiss the complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. §§ 1915(e)(2)(b), 1915A(b). The Court has thoroughly reviewed all factual allegations in the complaint and conducted an initial review of the allegations therein under 28 U.S.C. § 1915A. Based on this initial review, the Court orders as follows: The case will proceed on the claim for deliberate indifference to serious medical needs against Officer Sierra. I. FACTUAL ALLEGATIONS1 On September 21, 2023, at about 5:30 a.m., Mr. Figueroa allegedly experienced severe stomach pains. ECF No. 1 ¶ 1. He allegedly reported his symptoms to Officer Sierra, the third- shift officer. Id. ¶ 2. Officer Sierra allegedly stated, “I don’t give a f—k. You have to either wait for 1st shift or throw yourself on the floor and I’ll call a code white.” Id. ¶ 3.

Mr. Figueroa allegedly was unable to move and waited for the first shift officer. Id. ¶ 4. Mr. Figueroa allegedly reported his symptoms to the officer and was immediately sent to the medical unit. Id. ¶ 5. At sick call, the nurse allegedly checked Mr. Figueroa’s vital signs and noted that his blood pressure was low and he had a fever. Id. ¶ 6. The nurse allegedly sent Mr. Figueroa to UConn Health Center where he allegedly was diagnosed with a stomach infection and provided treatment. Id. ¶¶ 7–8.

II. DISCUSSION

To state a plausible Eighth Amendment claim, Mr. Figueroa must allege facts “showing the offending official’s ‘deliberate indifference to [his] serious medical needs.’” Thomas v. Wolf, 832 F. App’x 90, 92 (2d Cir. 2020) (quoting Hill v. Curcione, 657 F.3d 116, 122 (2d Cir. 2011)). There are two elements to a claim for deliberate indifference to medical needs. The first element is objective. The inmate must “show that he was ‘actually deprived of adequate medical care’ by an official’s failure ‘to take reasonable measures in response to a [sufficiently serious] medical condition.’” Id. (quoting Salahuddin v. Goord, 467 F.3d 263, 279-80 (2d Cir. 2006) (internal quotation marks omitted)). Establishing an objectively serious deprivation requires the court to

1 For purposes of initial review, the Court considers all of the following allegations to be true. make two separate inquiries. First, the court must determine whether the inmate “was actually deprived of adequate medical care.” Salahuddin, 467 F.3d at 279. The medical providers are only required to have “act[ed] reasonably.” Id. The second inquiry requires the court to determine “whether the inadequacy in medical care is sufficiently serious. This inquiry requires the court to

examine how the offending conduct is inadequate and what harm, if any, the inadequacy has caused or will likely cause the prisoner.” Id. at 280. Thus, although the objective element sometimes is referred to as the seriousness of the medical need, that is only one factor evaluated in determining the seriousness of the deprivation of medical care. See id. If the claim is for denial of any treatment, the court will consider “whether the inmate’s medical condition is sufficiently serious.” Id. A “sufficiently serious” deprivation can exist if the plaintiff suffers from an urgent medical condition that can cause death, degeneration, or extreme or chronic pain. See Brock v. Wright, 315 F.3d 158, 162–63 (2d Cir. 2003); Hathaway v. Coughlin, 99 F.3d 550, 553 (2d Cir. 1996). A medical condition may not initially be serious, but may become serious because it is degenerative and, if left untreated or neglected for a long

period of time, will “result in further significant injury or the unnecessary and wanton infliction of pain.” Harrison v. Barkley, 219 F.3d 132, 136–37 (2d Cir. 2000). The Second Circuit has identified several factors that are “highly relevant” to the question of whether a medical condition is sufficiently serious, including “an injury that a reasonable doctor or patient would find important and worthy of comment or treatment; the presence of a medical condition that significantly affects the individual’s daily activities; or the existence of chronic and substantial pain.” Chance v. Armstrong, 143 F.3d 698, 702 (2d Cir. 1998). If, however, the claim is for a delay in treatment, the court focuses on the challenged delay rather than merely on the underlying medical condition to determine whether the alleged deprivation is sufficiently serious. The court considers “the seriousness of the particular risk of harm that resulted from ‘the challenged delay or interruption in treatment rather than the prisoner’s underlying medical condition alone.’” Bellotto v. County of Orange, 248 Fed. App’x 232, 236 (2d Cir. 2007) (quoting Smith v. Carpenter, 316 F.3d 178, 185 (2d Cir. 2003)). “A

delay in treatment does not violate the constitution unless it involved an act or failure to act that evinces “a conscious disregard of a substantial risk of serious harm.” Rodriguez v. Doe, No. 3:22-CV-763(MPS), 2023 WL 184253, at *3 (D. Conn. Jan. 13, 2023) (citations and internal quotation marks omitted). The second element is subjective. The inmate must show “that the official acted with a culpable state of mind of ‘subjective recklessness,’ such that the official knew of and consciously disregarded ‘an excessive risk to inmate health or safety.’” Wolf, 832 F. App’x at 92 (citations omitted). Allegations constituting negligence or medical malpractice are insufficient to support an Eighth Amendment deliberate indifference claim. Id. (citing Hathaway v. Coughlin, 99 F.3d 550, 553 (2d Cir. 1996)); see also Walker v. Schult, 717 F.3d 119, 125 (2d Cir. 2013) (“mere

negligence’ is insufficient to state a claim for deliberate indifference).

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Related

Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Walker v. Schult
717 F.3d 119 (Second Circuit, 2013)
MYRIE v. Calvo
615 F. Supp. 2d 246 (S.D. New York, 2009)
Darnell v. City of New York
849 F.3d 17 (Second Circuit, 2017)
Hathaway v. Coughlin
99 F.3d 550 (Second Circuit, 1996)
Chance v. Armstrong
143 F.3d 698 (Second Circuit, 1998)
Harrison v. Barkley
219 F.3d 132 (Second Circuit, 2000)
Salahuddin v. Goord
467 F.3d 263 (Second Circuit, 2006)
Bell v. Jendell
980 F. Supp. 2d 555 (S.D. New York, 2013)

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Figueroa v. Sierra, Counsel Stack Legal Research, https://law.counselstack.com/opinion/figueroa-v-sierra-ctd-2024.