Adams v. County of San Mateo

Background

Ezra O. Adams, an inmate in the San Mateo County Jail proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against the County of San Mateo and the County Sheriff. The opinion also notes that Adams named County Correctional Health Services and the Sheriff’s Office; the court treated those entities as branches of the County. Adams was allowed to proceed without paying the filing fee in a separate order.

Adams alleged that he injured his shoulder while exercising at the jail. After hearing a pop, he experienced pain and limited movement. A jail doctor ordered an magnetic resonance imaging scan, but a nurse practitioner canceled it as “elective.” Adams received x-rays, was diagnosed with non-emergent arthrosis, and was told to seek further treatment after release. Another jail doctor and a jail orthopedist later ordered an MRI, but Adams alleged that he still had not received one eight months later and continued to have pain and limited use of his arm. He claimed deliberate indifference to serious medical needs in violation of the Fourteenth Amendment.

Screening standard

Because Adams is a prisoner seeking relief from governmental defendants, the court screened the complaint under 28 U.S.C. § 1915A. The court was required to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also explained that complaints filed without a lawyer are read liberally, but they must still include enough factual allegations to make a claim plausible.

To state a claim under § 1983, a plaintiff must allege both a violation of a federal constitutional or statutory right and conduct by a person acting under state law.

Claims against the Sheriff

The court held that Adams did not state a legally recognizable claim against the Sheriff because he did not allege that she was involved in his medical care or in any action or omission that caused the alleged deprivation. The Sheriff could not be held liable solely because of her supervisory position.

The court dismissed the claims against the Sheriff with leave to amend. It allowed Adams to try to cure the problem by alleging specific actions or omissions by the Sheriff that caused him not to receive adequate medical care. The court also said he could add claims against the nurse who canceled the MRI or other people if he alleged facts supporting a reasonable inference that their conduct amounted to deliberate indifference to his medical needs.

Claims against the County

The court held that Adams did not state a claim against the County because he did not allege a pattern or practice of inadequate medical care, which the court identified as an essential element of a § 1983 claim against a county. The court concluded that this claim could not be cured by amendment because Adams alleged that three jail doctors provided appropriate care by ordering the MRI. According to the court, those allegations did not support a reasonable inference that the County had a custom or policy of deliberate indifference to medical care.

The court dismissed the claims against the County without leave to amend.

Disposition

The court dismissed the complaint for failure to state a legally recognizable claim for relief. The claims against the County of San Mateo were dismissed without leave to amend, while the claims against the Sheriff were dismissed with leave to amend. Adams was permitted to file an amended complaint on or before November 13, 2024. The court warned that failure to amend as required could result in dismissal of the case.