Castillo v. Borla
- Pitt
- 5:24-cv-01245
- U.S. District Court · Northern District of California
- 8
In Castillo v. Borla, Judge Pitt dismissed claims against two defendants but allowed an inmate’s medical-care claims against two others to proceed.
The ruling allowed Gonzalo Castillo’s Eighth Amendment medical-care claims against Lauritzen and Bridgnell to proceed, while dismissing his claims against Ottenbacher and Posson without leave to amend.
What happened
In Gonzalo Castillo v. Edward Borla, et al., Gonzalo Castillo, an incarcerated person proceeding without a lawyer, alleged that repeated eye surgeries worsened his condition and that prison medical staff did not promptly arrange a new ophthalmologist.
The court dismissed Castillo’s claims against Ottenbacher and Posson because the amended complaint did not identify actions by either defendant supporting a claim. The court found that Castillo alleged enough to require Lauritzen and Bridgnell to respond to an Eighth Amendment claim concerning inadequate medical care.
Judge P. Casey Pitt ordered service of the amended complaint on Lauritzen and Bridgnell, and required defendants to file a summary-judgment motion or another dispositive motion within the time set by the order. The case therefore continued against those two defendants.
The detailed version
- Castillo v. Borla · No. 5:24-cv-01245
- Pitt
- July 17, 2025
Background
Gonzalo Castillo, an inmate at the Correctional Training Facility in Soledad, California, filed this civil-rights action under 42 U.S.C. § 1983 without a lawyer. The court had previously dismissed his original complaint for failure to state a claim, while allowing amendment as to some defendants.
Castillo’s amended complaint named Lauritzen, Bridgnell, Ottenbacher, and Posson. Castillo alleged that Lauritzen, an ophthalmologist, performed five surgeries on his left eye between February 24 and November 4, 2022, and that each surgery worsened the eye. He alleged that the repeated surgeries nearly caused the eye to die. Castillo also alleged that he told Bridgnell, his primary-care physician, about the problems and requested a new ophthalmologist, but Bridgnell did not promptly arrange one and allowed Lauritzen to perform a fifth surgery before a new ophthalmologist treated Castillo.
Screening standard
Because Castillo is a prisoner seeking relief from government officials, the court screened the amended complaint under 28 U.S.C. § 1915A. At screening, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also must read a complaint filed without a lawyer liberally.
Claims dismissed
The court dismissed Ottenbacher because the amended complaint did not allege that Castillo had any interaction with that defendant or identify any action by Ottenbacher supporting a claim. The court dismissed Posson because the amended complaint did not identify any direct action by Posson; the earlier complaint had accused Posson only of reviewing Castillo’s health-care grievances. The court dismissed these claims without leave to amend, as stated in the order.
Claims allowed to proceed
The court explained that deliberate indifference to a prisoner’s serious medical needs violates the Eighth Amendment. A claim requires a serious medical need and a response showing that the defendant knew of a substantial risk of serious harm and failed to take reasonable steps to address it. Mere negligence or medical malpractice is not enough, but a medically unacceptable course of treatment chosen in conscious disregard of an excessive health risk may support an Eighth Amendment claim.
The court concluded that Castillo alleged enough against Lauritzen to proceed because he alleged five surgeries, each of which worsened his eye, rather than a single mistake. The court also concluded that Castillo alleged enough against Bridgnell because he alleged that Bridgnell knew about the failed surgeries, received requests for a new ophthalmologist, delayed responding, and allowed a fifth surgery by Lauritzen. The court did not decide whether Castillo would ultimately prove these claims.
Order
The court ordered service of the amended complaint on Lauritzen and Bridgnell and ordered them to respond to Castillo’s Eighth Amendment deliberate-indifference claim. The order also set procedures for service, discovery, and later dispositive motions, including a summary-judgment motion. The court stated that all other claims and defendants did not remain in the action.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.