Price v. Sabbeen
- Jeffrey White
- 4:24-cv-02379
- U.S. District Court · Northern District of California
- 3
In Price v. Sabbeen, Judge White dismissed Price’s civil-rights claims for failure to state a claim and granted permission to proceed without paying fees.
Marcus A. Price’s civil-rights case was dismissed. The defendants were doctors at Napa State Hospital who had treated Price with Clozapine.
What happened
In Marcus A. Price v. Sabbeen, et al., Price, who was involuntarily committed at Napa State Hospital, sued hospital doctors under a federal civil-rights law. He challenged their refusal to stop treating him with the antipsychotic medication Clozapine because of its side effects.
Price represented himself and said the doctors should discontinue the medication. The court explained that a disagreement about medical treatment generally does not establish a constitutional violation, and found that Price had not plausibly alleged that the defendants violated his rights.
The court dismissed the claims for failure to state a claim for relief, directed the Clerk to enter judgment and close the case, and granted permission to proceed without paying filing fees. Judge Jeffrey White issued the order.
The detailed version
- Price v. Sabbeen · No. 4:24-cv-02379
- Jeffrey White
- July 8, 2024
Background
Marcus A. Price, proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against doctors at Napa State Hospital. The opinion states that Price had been involuntarily committed at the hospital since 2019 after being found not guilty of criminal charges by reason of insanity. The doctors treated him with Clozapine, an antipsychotic medication. Price alleged that they denied his requests to discontinue the medication because of its adverse side effects.
The court granted Price permission to proceed without paying filing fees because he lacked funds. Under the screening statute for such cases, 28 U.S.C. § 1915(e)(2), the court may dismiss an action that is frivolous, fails to state a claim for relief, or seeks money from an immune defendant.
Legal standard
The court explained that a § 1983 claim requires allegations showing both that a federal constitutional or statutory right was violated and that the violation was committed by someone acting under state law. It also explained that a complaint must include enough factual matter to make the claimed right to relief plausible, although courts must read complaints filed by people without lawyers liberally.
Court’s analysis
The court held that Price’s allegations did not state a cognizable claim. In the court’s view, a disagreement between Price and the defendant doctors about whether it was medically proper to continue Clozapine despite its side effects did not establish deliberate indifference, which the court identified as a required element of the asserted Eighth Amendment claim. The court cited decisions stating that a disagreement between a patient and medical authorities, or between medical professionals, about treatment is insufficient by itself to establish deliberate indifference.
The court concluded that, even construing the complaint liberally, Price had not alleged facts plausibly showing that any defendant violated his Eighth Amendment rights.
Disposition
The court dismissed Price’s claims for failure to state a cognizable claim for relief. It directed the Clerk to enter judgment and close the file. The order also granted Price permission to proceed without paying filing fees.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.