Ronald Eugene James v. Ma

• Court: District Court, E.D. California
• Decided: September 19, 2025
• Docket: 2:24-cv-02193
• Status: Unknown

Opinion

1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 RONALD EUGENE JAMES, No. 2:24-CV-2193-KJM-DMC-P 12 Plaintiff, ORDER 13 v. 14 MA, 15 Defendant. 16 17 Plaintiff, a prisoner proceeding pro se, brings this civil rights action under 42 U.S.C. 18 § 1983. The matter was referred to a United States Magistrate Judge pursuant to Eastern District 19 of California local rules. 20 On August 8, 2025, the Magistrate Judge filed findings and recommendations, which were 21 served on the parties, and which contained notice that the parties may file objections within the 22 time specified therein. See ECF No. 30. Timely objections to the findings and recommendations 23 have been filed. See ECF No. 34. 24 In accordance with the provisions of 28 U.S.C. § 636(b)(1)(C) and Local Rule 304(f), this 25 court has conducted a de novo review of this case. Having reviewed the file, the court agrees 26 with the magistrate judge’s conclusions albeit on different grounds. 27 As plaintiff notes in his objections, his claim of deliberately indifferent medical care arises 28 under the Fourteenth Amendment as he was a pretrial detainee in the Sacramento County Jail, and 1 not under the Eighth Amendment, as the magistrate judge indicated in his findings and 2 recommendations. See Objs. at 1, ECF No. 34. The court notes defendant appears to agree with 3 plaintiff’s objection as defendant articulated the standard for deliberately indifferent medical care 4 arising under the Fourteenth Amendment in her motion to dismiss. See ECF No. 18-1 at 3–5; see 5 also Reply at 1–2, ECF No. 23. The difference between an Eighth Amendment claim and a 6 Fourteenth Amendment claim is important because a claim arising under the Eighth Amendment 7 requires the plaintiff show the defendant failed to meet an objective standard of care and 8 possessed a subjective intent to cause plaintiff harm, or a “sufficiently culpable mind.” F&Rs at 4 9 (quoting Farmer v. Brennan, 511 U.S. 825, 832 (1994)). A Fourteenth Amendment claim, 10 however, only is evaluated under an “objective deliberate indifference standard.” Gordon v. 11 County of Orange, 888 F.3d 1118, 1124–25. 12 For a Fourteenth Amendment claim alleging a violation of the right to adequate medical 13 care to survive a motion to dismiss, the plaintiff must plausibly allege:

14 (i) the defendant made an intentional decision with respect to the 15 conditions under which the plaintiff was confined; (ii) those conditions put the plaintiff at substantial risk of suffering serious 16 harm; (iii) the defendant did not take reasonable available measures to abate that risk, even though a reasonable official in the 17 circumstances would have appreciated the high degree of risk involved—making the consequences of the defendant’s conduct 18 obvious; and (iv) by not taking such measures, the defendant caused 19 the plaintiff’s injuries. Id. at 1125. Under the third prong of this test, the plaintiff must allege “more than negligence but 20 less than subjective intent—something akin to reckless disregard.” Id. at 1071 (quoting Castro v. 21 County of Los Angeles, 833 F.3d 1060, 1071 (9th Cir. 2016)). 22 While the court disagrees with the magistrate judge’s recommendation as articulated, it 23 otherwise agrees with the magistrate judge’s analysis of plaintiff’s claim and, drawing on that 24 analysis while applying the proper standard for pleading inadequate medical care under the 25 Fourteenth Amendment, finds plaintiff has made out a plausible claim and denies defendant’s 26 motion to dismiss. In brief, plaintiff alleges defendant made an intentional decision to not supply 27 plaintiff with medication even though he was experiencing symptoms of a heart attack and after 28 1 plaintiff, who had had two previous heart attacks, told defendant he had run out of his heart 2 medication. See Am. Compl. at 4, ECF No. 11. Further, defendant did not schedule a follow-up 3 appointment with plaintiff after sending him back to his housing location. See id. Defendant’s 4 decisions may have put plaintiff at substantial risk of suffering a major heart attack given 5 plaintiff’s symptoms and previous medical history. A reasonable official in these circumstances 6 would have provided plaintiff with medication and/or scheduled a follow-up appointment to 7 avoid such a disastrous consequence as a heart attack. Finally, the defendant caused plaintiff 8 harm as he sustained heart palpitations and shortness of breath as well as mental anguish as a 9 consequence of defendant’s actions. See id. at 4–5. 10 Defendant argues she gave plaintiff medical treatment: she provided him, for an example, 11 an EKG test. See Mem. at 4–5. Yet crediting plaintiff’s allegations, he has not necessarily pled a 12 case in which medical opinions could differ given that plaintiff already was taking heart 13 medication and had a series of previous serious heart-related issues. Given the allegations, 14 plaintiff may ultimately be able to persuade a jury defendant’s actions were “medically 15 unacceptable under the circumstances.” F&Rs at 6; cf. Jett v. Penner, 439 F.3d 1091, 1098 (9th 16 Cir. 2006) (holding claim under which jury could infer defendant’s course of action was 17 medically unacceptable survived summary judgment). Finally, defendant argues plaintiff has not 18 pled a physical injury that meets the threshold requirement of the Prison Litigation Reform Act 19 (PLRA). See Mem. at 4–5 (citing 42 U.S.C. §§ 1997e(e)). The court disagrees, however, and 20 adopts the magistrate judge’s recommendation that plaintiff has pled a physical injury sufficient 21 to meet the requirements of the PLRA. See F&Rs at 6–7. 22 Accordingly, IT IS HEREBY ORDERED as follows: 23 1. The findings and recommendations filed August 8, 2025, ECF No. 30, are 24 adopted to the extent explained above, applying the appropriate Fourteenth Amendment 25 standard. 26 2. Defendant’s motion to dismiss, ECF No. 18, is denied. 27 3. Defendant shall file an answer to plaintiff’s first amended complaint within 28 30 days of the date of this order. 1 4. This matter is referred back to the assigned Magistrate Judge for further 2 proceedings. 3 This order resolves ECF Nos. 18, 30. 4 IT IS SO ORDERED. 5 DATED: September 18, 2025. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28