Salmon v. Skagit County Jail

CourtDistrict Court, W.D. Washington
DecidedMay 16, 2023
Docket2:23-cv-00633
StatusUnknown

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

Bluebook
Salmon v. Skagit County Jail, (W.D. Wash. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT TACOMA 6 TROY E SALMON, Case No. 2:23-cv-00633-JNW-TLF 7 Plaintiff, v. ORDER TO SHOW CAUSE, OR 8 PROVIDING LEAVE TO FILE AN SKAGIT COUNTY JAIL, AMENDED COMPLAINT 9 Defendants. 10

11 This matter comes before the Court on pro se Plaintiff Troy Salmon’s motion to 12 proceed in forma pauperis. Dkt. 4. Plaintiff filed a civil rights complaint under 42 U.S.C. 13 § 1983. Having reviewed and screened Plaintiff’s Complaint under 28 U.S.C. §1915A, 14 the Court finds the complaint fails to state a claim as to Skagit County Medical 15 Department. But the Court provides Plaintiff leave to file an amended pleading by June 16 9, 2023 to cure the deficiencies identified herein. The Clerk is instructed to re-note 17 Plaintiff’s motion to proceed in forma pauperis to June 9, 2023. 18 BACKGROUND 19 Plaintiff filed his proposed complaint on May 11, 2023, alleging § 1983 claims 20 arising while he was at the Skagit County Jail. Dkt. 4-1. He states he is convicted and 21 sentenced state prisoner. Plaintiff contends that Skagit County Jail Medical Department, 22 the only named defendant, improperly denied him treatment and medications that were 23 already approved. Id. at 4. Plaintiff asserts he has cervical stenosis, degenerative 24 1 arthritis, and neuropathy, and was unable to see a provider for five weeks. Id. at 5. 2 Plaintiff alleges that when he did see a provider, the provider did not prescribe the 3 proper medications. Id. Plaintiff asserts he has suffered pain; he requests monetary 4 damages from Defendant as well as payment for future treatments and specialists. Id. at

5 6. 6 DISCUSSION 7 Under the Prison Litigation Reform Act of 1995, the Court is required to screen 8 complaints brought by prisoners seeking relief against a governmental entity or officer 9 or employee of a governmental entity. 28 U.S.C. § 1915A(a). The Court must “dismiss 10 the complaint, or any portion of the complaint, if the complaint: (1) is frivolous, 11 malicious, or fails to state a claim upon which relief may be granted; or (2) seeks 12 monetary relief from a defendant who is immune from such relief.” Id. at (b); 28 U.S.C. § 13 1915(e)(2); see Barren v. Harrington, 152 F.3d 1193 (9th Cir. 1998). 14 I. Inadequate Medical Treatment

15 Plaintiff alleges that Defendant failed to give him proper medical treatment for his 16 ailments. Based on this, it appears Plaintiff seeks to allege a violation of his Eighth 17 Amendment or Fourteenth Amendment rights. 18 When a claim of inadequate medical care is brought by a pretrial detainee, the 19 claim arises under the Due Process Clause of the Fourteenth Amendment. Gordon v. 20 County of Orange, 888 F.3d 1118, 1124-25 (9th Cir. 2018). 21 To state a Fourteenth Amendment claim relating to medical care of a pre-trial 22 detainee, a plaintiff must include factual allegations that a state actor acted, or failed to 23

24 1 act, in a manner that shows deliberate indifference to their serious medical needs. 2 Gordon v. County of Orange, at 1124-25. 3 The elements are:“(i) the defendant made an intentional decision with respect to the conditions under which the plaintiff was confined; (ii) those conditions put the 4 plaintiff at substantial risk of suffering serious harm; (iii) the defendant did not take reasonable available measures to abate that risk, even though a reasonable 5 official in the circumstances would have appreciated the high degree of risk involved – making the consequences of the defendant’s conduct obvious; and 6 (iv) by not taking such measures, the defendant caused the plaintiff’s injuries.”

7 Id., at 1125. The defendant’s conduct must be objectively unreasonable; concerning 8 element (iii), plaintiff is required to show more than negligence, but less than subjective 9 intent – “something akin to reckless disregard.” Id. (citations and internal quotations 10 omitted). 11 If Plaintiff files an amended complaint, he should clarify whether all or part of his 12 allegations would be Fourteenth Amendment claims because the facts occurred before 13 his conviction; or whether his allegations would be an Eighth Amendment claim 14 because the facts occurred after a trial or guilty plea – in other words, after he was 15 convicted. 16 The Eighth Amendment proscribes deliberate indifference to a prisoner’s serious 17 medical needs; it applies to persons who have been convicted of an offense. Estelle v. 18 Gamble, 429 U.S. 97, 103 (1976). “[T]o maintain an Eighth Amendment claim based on 19 prison medical treatment, an inmate must show ‘deliberate indifference to serious 20 medical needs.’ ” Jett v. Penner, 439 F.3d 1091, 1096 (9th Cir.2006) (quoting Estelle v. 21 Gamble, 429 U.S. 97, 106 (1976)). The two-part test for deliberate indifference requires 22 the plaintiff to show (1) “ ‘a serious medical need’ by demonstrating that ‘failure to treat 23 a prisoner's condition could result in further significant injury or the unnecessary and 24 1 wanton infliction of pain,’ ” and (2) “the defendant's response to the need was 2 deliberately indifferent.” Jett, 439 F.3d at 1096 (quoting McGuckin v. Smith, 974 F.2d 3 1050, 1059 (9th Cir.1992), overruled on other grounds, WMX Techs., Inc. v. Miller, 104 4 F.3d 1133, 1136 (9th Cir.1997) (en banc)). Deliberate indifference is shown by “a

5 purposeful act or failure to respond to a prisoner's pain or possible medical need, and 6 harm caused by the indifference.” Jett, 439 F.3d at 1096 (citing McGuckin, 974 F.2d at 7 1060). In order to state a claim for violation of the Eighth Amendment, a plaintiff must 8 allege sufficient facts to support a claim that the named defendants “[knew] of and 9 disregard[ed] an excessive risk to [Plaintiff's] health ....” Farmer v. Brennan, 511 U.S. 10 825, 837(1994). 11 In applying this standard, the Ninth Circuit has held that before it can be said that 12 a prisoner's civil rights have been abridged, “the indifference to his medical needs must 13 be substantial. Mere ‘indifference,’ ‘negligence,’ or ‘medical malpractice’ will not support 14 this cause of action.” Broughton v. Cutter Laboratories, 622 F.2d 458, 460 (9th

15 Cir.1980) (citing Estelle, 429 U.S. at 105–06). “[A] complaint that a physician has been 16 negligent in diagnosing or treating a medical condition does not state a valid claim of 17 medical mistreatment under the Eighth Amendment. Medical malpractice does not 18 become a constitutional violation merely because the victim is a prisoner.” Estelle, 429 19 U.S. at 106; see also Anderson v. County of Kern, 45 F.3d 1310, 1316 (9th Cir.1995); 20 McGuckin, 974 F.2d at 1050, overruled on other grounds, WMX, 104 F.3d at 1136. 21 Even gross negligence is insufficient to establish deliberate indifference to serious 22 medical needs. See Wood v.

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Salmon v. Skagit County Jail, Counsel Stack Legal Research, https://law.counselstack.com/opinion/salmon-v-skagit-county-jail-wawd-2023.