(PC) Hunt v. Oberst

CourtDistrict Court, E.D. California
DecidedDecember 14, 2020
Docket1:20-cv-00475
StatusUnknown

This text of (PC) Hunt v. Oberst ((PC) Hunt v. Oberst) 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) Hunt v. Oberst, (E.D. Cal. 2020).

Opinion

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10

11 RONALD DESHAUN HUNT, CASE NO. 1:20-cv-0475 JLT (PC)

12 Plaintiff, ORDER DIRECTING PLAINTIFF TO FILE A RESPONSE 13 v. (Doc. 11) 14 DR. OBERST, Defendant. THIRTY-DAY DEADLINE 15

16 17 Plaintiff has filed a first amended complaint asserting constitutional claims against a 18 governmental employee. (Doc. 11.) Generally, the Court is required to screen complaints brought 19 by inmates seeking relief against a governmental entity or an officer or employee of a governmental 20 entity. 28 U.S.C. § 1915A(a). The Court must dismiss a complaint or portion thereof if the prisoner 21 has raised claims that are legally “frivolous or malicious,” that fail to state a claim upon which relief 22 may be granted, or that seek monetary relief from a defendant who is immune from such relief. 28 23 U.S.C. § 1915A(b)(1), (2). “Notwithstanding any filing fee, or any portion thereof, that may have 24 been paid, the court shall dismiss the case at any time if the court determines that . . . the action or 25 appeal . . . fails to state a claim upon which relief may be granted.” 28 U.S.C. § 1915(e)(2)(B)(ii). 26 I. Pleading Standard 27 A complaint must contain “a short and plain statement of the claim showing that the pleader 28 1 is entitled to relief. . . .” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not required, but

2 “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements,

3 do not suffice,” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atlantic Corp. v. Twombly,

4 550 U.S. 544, 555 (2007)), and courts “are not required to indulge unwarranted inferences,” Doe I

5 v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation marks and citation

6 omitted). While factual allegations are accepted as true, legal conclusions are not. Iqbal, 556 U.S.

7 at 678.

8 Prisoners may bring § 1983 claims against individuals acting “under color of state law.”

9 See 42 U.S.C. § 1983, 28 U.S.C. § 1915(e) (2)(B)(ii). Under § 1983, Plaintiff must demonstrate that

10 each defendant personally participated in the deprivation of his rights. Jones v. Williams, 297 F.3d

11 930, 934 (9th Cir. 2002). This requires the presentation of factual allegations sufficient to state a

12 plausible claim for relief. Iqbal, 556 U.S. at 678-79; Moss v. U.S. Secret Service, 572 F.3d 962, 969

13 (9th Cir. 2009). Prisoners proceeding pro se in civil rights actions are entitled to have their pleadings

14 liberally construed and to have any doubt resolved in their favor, Hebbe v. Pliler, 627 F.3d 338, 342

15 (9th Cir. 2010) (citations omitted), but nevertheless, the mere possibility of misconduct falls short

16 of meeting the plausibility standard, Iqbal, 556 U.S. at 678; Moss, 572 F.3d at 969.

17 II. Plaintiff’s Allegations

18 Plaintiff bring this suit against Dr. Oberst, a medical doctor at the California Substance

19 Abuse Treatment Facility in Corcoran, California. Plaintiff alleges that he has a history of seizure

20 disorder and traumatic brain injury. After experiencing seizures for a few days, plaintiff was seen

21 by Dr. Oberst, who is not plaintiff’s regular doctor. Dr. Oberst informed plaintiff that he would

22 increase the dosage of plaintiff’s seizure medication, Dialantin, but plaintiff verbally opposed the

23 increase. It is unclear if plaintiff informed Dr. Oberst that the reason he was declining the increase

24 was because of prior experience with Dialantin, which causes his gums to bleed and makes him

25 dizzy when the dosage is too high.

26 Plaintiff later went to pill call and learned that his medication had indeed been changed.

27 Plaintiff took the new pills as prescribed, but he suffered multiple seizures and was hospitalized for

28 1 medication toxicity. Plaintiff claims that Dr. Oberst violated his right to refuse medication. Plaintiff

2 seeks injunctive relief and damages.

3 III. Discussion

4 A. Fourteenth Amendment Right to Refuse Treatment

5 Plaintiff’s contention that his right to refuse treatment was violated is, liberally construed,

6 a Fourteenth Amendment substantive due process claim.

7 Substantive due process refers to certain actions that the government may not engage in, no

8 matter how many procedural safeguards it employs. See County of Sacramento v. Lewis, 523 U.S.

9 833, 847 (1998); Blaylock v. Schwinden, 862 F.2d 1352, 1354 (9th Cir. 1988). Due process

10 protection in the substantive sense limits what the government may do in both its legislative and

11 executive capacities. See Lewis, 523 U.S. at 846. “Only official conduct that ‘shocks the conscience’

12 is cognizable as a due process violation.” Porter v. Osborn, 952 F.3d 1131, 1137 (9th Cir. 2008)

13 (quoting Lewis, 523 U.S. at 846).

14 Substantive due process must be expanded only with the greatest care and its protection is

15 primarily reserved for liberties deeply rooted in the nation’s history and tradition, see Doe v.

16 Tandeske, 361 F.3d 594, 597 (9th Cir. 2004) (per curiam); that is, it is ordinarily reserved for those

17 rights that are “fundamental,” see Washington v. Glucksberg, 521 U.S. 702, 721-22 (1997). “The

18 protections of substantive due process have for the most part been accorded to matters relating to

19 marriage, family, procreation, and the right to bodily integrity.” Albright v. Oliver, 510 U.S. 266,

20 271-72 (1994).

21 It is undisputed that there is a federally recognized liberty interest in the right to bodily

22 integrity under the Fourteenth Amendment. Ingraham v. Wright, 430 U.S. 651, 673-74 (1977).

23 However, Ingraham addressed the rights of schoolchildren to remain free from arbitrary physical

24 punishment. Id. In Cruzen v. Missouri, the Supreme Court confirmed that “a competent person has

25 a constitutionally protected liberty interest in refusing unwanted medical treatment.” 497 U.S. 261,

26 278 (1990). However, Cruzen specifically dealt with, and assumed for purposes of the case, that the

27 Constitution “would grant a competent person a constitutionally protected right to refuse lifesaving

28 1 hydration and nutrition.” Id. at 279.

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