Court Revives California Prisoner's Medical Claim
(CN) - A federal judge improperly found that the longstanding class action over overcrowded California prisons encompasses the deliberate indifference claims of a Calipatria prisoner, the 9th Circuit ruled Tuesday.
When Calipatria prisoner David Pride sued over deliberate indifference to his medical needs, a federal judge in San Diego had concluded that Plata v. Brown encompassed his claims.
It has been over a decade since Marciano Plata filed a 2001 action to improve conditions for California prisoners with serious medical conditions. His case had been consolidated with Ralph Coleman's 1990 federal class action on behalf of seriously mentally ill inmates.
A three-judge panel for California's Eastern and Northern Districts concluded in 2009 that California needed to alleviate these wrongs by reducing its prison population to 137.5 percent of capacity, but left state officials to come up with a specific plan. California appealed the order, arguing that the panel was convened prematurely and that the substance of the order was improper.
Though a five-justice majority of the U.S. Supreme Court affirmed the order in 2011, Justice Antonin Scalia decried the entire proceedings as "a judicial travesty," and Justice Samuel Alito wrote that "the Constitution does not give federal judges the authority to run state penal systems."
California has reduced its inmate population by more than 46,000 since 2006. The 2011 Prison Realignment Act, which sentences nonviolent, nonserious felons to county jails rather than state prison, accounts for more than half of that number. Still, the population remains 9,400 over the capacity mandate.
After the District Courts panel refused to modify its order in April 2013, state officials submitted an inmate-reduction plan the next month.
Finding that plan inadequate in June, the panel gave California a deadline of Dec. 31, 2013, to release 10,000 prisoners or face contempt charges.
Pride's pro se complaint meanwhile alleges that old gunshot wounds left his shoulder permanently out of commission and that an old sports injury also causes his knee to slide out of joint, resulting in pain and swelling.
Though a prison doctor at Pelican Bay allegedly prescribed Pride a double mattress and a knee brace for his injuries, the inmate has been unable to receive such amenities upon transfer to Calipatria State Prison.
Pride says Calipatria has not accommodated him even though a prison doctor there prescribed him knee braces and an egg crate mattress.
The 9th Circuit concluded Tuesday that Plata has no bearing on Pride's claims. While Plata seeks systemic reform of medical care in California prisons, Pride's "claim for injunctive relief concerns only his individual medical care," according to the ruling from Pasadena.
"In dismissing Pride's claim for injunctive relief, the District Court adopted the reasoning of Gary v. Hawthron, (S.D. Cal. Sept. 19, 2007)," Judge Harry Pregerson wrote for the panel. "In that case, however, the prisoner's claim for injunctive relief requested 'better medical staffing and screening procedures for all prison inmates.' The prisoner's claim for injunctive relief thus sought systemic medical care reform, which as Gary correctly concluded, is already provided for in Plata. Unlike the prisoner in Gary, Pride's claim for injunctive relief relates solely to his individual need for medical treatment." (Emphasis added by appellate panel.)