Price v. Mann

Background

Marcus A. Price, who is civilly committed at Napa State Hospital, filed a civil-rights complaint under 42 U.S.C. § 1983 against staff members of the hospital. He represented himself. Price alleged that Dr. Mann, Dr. Sabeen, and two other staff members failed to provide treatment for his suicidal thoughts.

Screening and Claims Allowed to Proceed

Because Price showed that he lacked funds, the court granted him permission to proceed without prepaying filing fees. The court explained that complaints filed by people proceeding without prepaying fees must be dismissed if the allegations are untrue, frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also said that self-represented complaints must be read liberally, while still providing enough facts to make a claim plausible.

The court held that, when read liberally, Price stated cognizable claims against Dr. Mann and Dr. Sabeen for violating his Eighth Amendment rights by failing to treat his suicidal thoughts. The court ordered the Clerk to issue summonses and the United States Marshal to serve those defendants without prepayment of fees. The order also directed service on the California Department of State Hospitals, which the opinion says runs Napa State Hospital, and directed that a courtesy copy be sent to the California Attorney General’s Office.

Unidentified Defendants

Price also alleged that two other Napa State Hospital staff members denied him treatment. He identified one as “Nicole Rec Therapist” and the other as “BJ (medical staff).” The court found that their last names were needed so the Marshal could serve them. Price was ordered to submit their last names by August 8, 2024. If he failed to do so, the claims against those two defendants would be dismissed without prejudice.

Case Schedule and Ruling

The court ordered the defendants to file a summary-judgment motion or another dispositive motion by October 9, 2024, unless they informed the court that the case could not be resolved through summary judgment. Price’s opposition was due November 9, 2024, and the defendants’ reply was due November 23, 2024. The court stated that no hearing would be held unless it later ordered one. The parties could conduct discovery under the Federal Rules of Civil Procedure.

Judge Jeffren S. White therefore granted leave to proceed without prepaying fees, ordered service of the claims against Dr. Mann and Dr. Sabeen, and required additional identifying information for the two unnamed staff members.