(PC) Harper v. Farhat

CourtDistrict Court, E.D. California
DecidedJanuary 21, 2025
Docket2:24-cv-02644
StatusUnknown

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

Bluebook
(PC) Harper v. Farhat, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 DARCY HARPER, No. 2:24-cv-2644 CSK P 12 Plaintiff, 13 v. ORDER AND FINDINGS AND RECOMMENDATIONS 14 ALEX FARHAT, et al., 15 Defendants. 16 17 I. INTRODUCTION 18 Plaintiff is a state prisoner, proceeding without counsel, with a civil rights action pursuant 19 to 42 U.S.C. § 1983. Pending before the Court is plaintiff’s second amended complaint. (ECF 20 No. 14.) For the following reasons, this Court recommends dismissal of plaintiff’s claim alleging 21 that defendant Ekinim violated the Eighth Amendment when she gave plaintiff the wrong dose of 22 insulin. This Court separately orders service of the remaining claims raised in the second 23 amended complaint: 1) claim one alleging that defendant Farhat failed to treat plaintiff for side 24 effects caused by the Covid-19 vaccine; 2) claim three alleging that defendant Singh failed to 25 refer plaintiff to wound care for treatment of plaintiff’s right foot; and 3) claim four alleging that 26 defendant Ekinim failed to provide plaintiff with medical care after giving plaintiff the wrong 27 dose of insulin. 28 /// 1 II. SCREENING STANDARDS 2 The court is required to screen complaints brought by prisoners seeking relief against a 3 governmental entity or officer or employee of a governmental entity. 28 U.S.C. § 1915A(a). The 4 court must dismiss a complaint or portion thereof if the prisoner raised claims that are legally 5 “frivolous or malicious,” that fail to state a claim upon which relief may be granted, or that seek 6 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915A(b)(1), (2). 7 A claim is legally frivolous when it lacks an arguable basis either in law or in fact. 8 Neitzke v. Williams, 490 U.S. 319, 325 (1989); Franklin v. Murphy, 745 F.2d 1221, 1227-28 (9th 9 Cir. 1984). The court may, therefore, dismiss a claim as frivolous when it is based on an 10 indisputably meritless legal theory or where the factual contentions are clearly baseless. Neitzke, 11 490 U.S. at 327. The critical inquiry is whether a constitutional claim, however inartfully 12 pleaded, has an arguable legal and factual basis. See Jackson v. Arizona, 885 F.2d 639, 640 (9th 13 Cir. 1989), superseded by statute as stated in Lopez v. Smith, 203 F.3d 1122, 1130-31 (9th Cir. 14 2000) (“[A] judge may dismiss [in forma pauperis] claims which are based on indisputably 15 meritless legal theories or whose factual contentions are clearly baseless.”); Franklin, 745 F.2d at 16 1227. 17 Rule 8(a)(2) of the Federal Rules of Civil Procedure “requires only ‘a short and plain 18 statement of the claim showing that the pleader is entitled to relief,’ in order to ‘give the 19 defendant fair notice of what the . . . claim is and the grounds upon which it rests.’” Bell Atlantic 20 Corp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957)). 21 In order to survive dismissal for failure to state a claim, a complaint must contain more than “a 22 formulaic recitation of the elements of a cause of action;” it must contain factual allegations 23 sufficient “to raise a right to relief above the speculative level.” Bell Atlantic, 550 U.S. at 555. 24 However, “[s]pecific facts are not necessary; the statement [of facts] need only ‘give the 25 defendant fair notice of what the . . . claim is and the grounds upon which it rests.’” Erickson v. 26 Pardus, 551 U.S. 89, 93 (2007) (quoting Bell Atlantic, 550 U.S. at 555, citations and internal 27 quotations marks omitted). In reviewing a complaint under this standard, the court must accept as 28 true the allegations of the complaint in question, Erickson, 551 U.S. at 93, and construe the 1 pleading in the light most favorable to the plaintiff. Scheuer v. Rhodes, 416 U.S. 232, 236 2 (1974), overruled on other grounds, Davis v. Scherer, 468 U.S. 183 (1984). 3 III. LEGAL STANDARD FOR EIGHTH AMENDMENT INADEQUATE MEDICAL 4 CARE CLAIM 5 Plaintiff’s second amended complaint raises claims alleging inadequate medical care. 6 “Deliberate indifference to a prisoner’s serious medical needs violates the Eighth Amendment's 7 proscription against cruel and unusual punishment.” Estelle v. Gamble, 429 U.S. 97, 104 (1976). 8 To prevail on such a claim, a prisoner-plaintiff must show he or she had a “serious medical need” 9 and that the defendants’ “response to the need was deliberately indifferent.” Jett v. Penner, 439 10 F.3d 1091, 1096 (9th Cir. 2006). 11 A prison official is deliberately indifferent if the “official knows that inmates face a 12 substantial risk of serious harm and disregards that risk by failing to take reasonable measures to 13 abate it.” Farmer v. Brennan, 511 U.S. 825, 847 (1994). An official is liable if the official 14 “knows of and disregards an excessive risk to inmate health or safety; the official must both be 15 aware of facts from which the inference could be drawn that a substantial risk of serious harm 16 exists, and he must also draw the inference.” Id. at 837. So, for deliberate indifference to be 17 established, there must be a purposeful act or failure to act on the part of the defendant and 18 resulting harm. Simmons v. G. Arnett, 47 F.4th 927, 933 (9th Cir. 2022). A claim of medical 19 malpractice or negligence does not give rise to a Section 1983 claim. See Toguchi v. Chung, 391 20 F.3d 1051, 1060 (9th Cir. 2004). Neither does a “difference of opinion between a prisoner-patient 21 and prison medical authorities regarding treatment.” Franklin v. Oregon, 662 F.2d 1337, 1344 22 (9th Cir. 1981). 23 IV. DISCUSSION 24 The second amended complaint identifies four claims. 25 A. Claim One 26 Plaintiff alleges that defendant Dr. Farhat violated plaintiff’s Eighth Amendment right to 27 adequate medical care by failing to treat plaintiff for side effects caused by the Covid-19 vaccine. 28 (ECF No. 14 at 3.) Plaintiff alleges that after plaintiff took the first Covid-19 vaccine, plaintiff 1 began having problems. (Id.) Plaintiff reported his reactions to the vaccine to defendant Farhat. 2 (Id.) Defendant Farhat laughed at plaintiff and said that plaintiff was hallucinating. (Id.) After 3 plaintiff got the second Covid-19 vaccine, plaintiff got worse. (Id.) Defendant Farhat ignored 4 plaintiff and transferred plaintiff to another unit, stating that plaintiff was having mental health 5 issues. (Id.) Plaintiff alleges that the staff in the new unit refused to listen to plaintiff based on 6 what defendant Farhat told them until plaintiff was swollen and unable to walk.

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Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Scheuer v. Rhodes
416 U.S. 232 (Supreme Court, 1974)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Rhodes v. Chapman
452 U.S. 337 (Supreme Court, 1981)
Davis v. Scherer
468 U.S. 183 (Supreme Court, 1984)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Washington v. Harper
494 U.S. 210 (Supreme Court, 1990)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Harry Franklin v. Ms. Murphy and Hoyt Cupp
745 F.2d 1221 (Ninth Circuit, 1984)
Javiad Akhtar v. J. Mesa
698 F.3d 1202 (Ninth Circuit, 2012)
Farmer v. Brennan
511 U.S. 825 (Supreme Court, 1994)
Philip Rosati v. Dr. Igbinoso
791 F.3d 1037 (Ninth Circuit, 2015)
Campbell v. Wood
20 F.3d 1050 (Ninth Circuit, 1994)

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