Harrison v. Singh

Background

James Ruhallah Harrison, who was housed at Correctional Training Facility, filed this civil-rights action under 42 U.S.C. § 1983. He alleged that Mandeep Singh, a doctor, failed to treat or inadequately treated pain in his right shoulder, violating the Eighth Amendment. On February 20, 2024, the court granted summary judgment in Singh’s favor.

Harrison later filed a pleading challenging that judgment and requesting a hearing, an order to show cause, and the testimony of Dr. Duc Nguyen. The court treated the pleading as a motion for reconsideration.

Harrison’s Arguments

Harrison argued that Singh knew he had a rotator cuff tear and failed to provide necessary treatment. He pointed to Singh’s diagnosis of rotator tendinitis, denials of requests for an MRI, and the later MRI ordered by Dr. Nguyen, which showed a full-thickness rotator cuff tear. Harrison also asserted that Dr. Nguyen was willing to testify that Singh knew about the tear and intentionally provided inadequate care.

Court’s Analysis

The court explained that reconsideration is an extraordinary remedy available only for specified reasons, such as mistake, newly discovered evidence, fraud, a void judgment, satisfaction of the judgment, or other extraordinary circumstances. A party cannot use reconsideration merely to reargue the case or present evidence that should have been offered earlier.

The court found that Harrison did not show that the earlier summary-judgment decision was mistaken or that extraordinary circumstances justified reopening the case. According to the court, Singh treated Harrison’s shoulder at each appointment and adjusted or escalated treatment in response to his reported symptoms. The treatments identified by the court included a steroid injection, an x-ray, physical therapy, and a referral for an orthopedic-surgery evaluation.

The court acknowledged that Singh was incorrect in concluding that Harrison did not have a rotator cuff tear. But it found no record evidence showing that Singh knew Harrison had a tear and deliberately said otherwise, or that she knew her treatment exposed him to a serious risk of serious harm. The court also found that the cited medical records did not prove deliberate indifference, which requires more than awareness of facts from which a serious risk could be inferred; the provider must also draw that inference. Harrison’s assertion about Dr. Nguyen’s possible testimony was insufficient without a declaration, and the court stated that the testimony was not newly discovered evidence because it should have been presented when Harrison opposed summary judgment.

The court rejected Harrison’s request for an evidentiary hearing and an order to show cause. It explained that 18 U.S.C. § 3626(a) concerns prisoner-release orders and injunctive relief involving prison conditions, not such hearings or orders. It also found that the cited immigration case did not apply because it concerned stays of removal.

Ruling

Judge Tigar denied Harrison’s motion for reconsideration. The order did not reopen the case; it stated that the case remains closed and terminated the motion identified as ECF No. 42.