Hartley v. Bright

Background

Roger Andrew Hartley, an incarcerated person at the California Institute for Men, filed this civil-rights action without a lawyer under 42 U.S.C. § 1983 concerning events at Salinas Valley State Prison. The court had previously dismissed his original complaint for failing to state a claim, dismissed the action after his first amended complaint appeared to show that the claims were time-barred, and later reopened the case after Hartley explained that the events occurred more recently than stated in the first amended complaint.

Hartley’s Second Amended Complaint named D. Bright and California Correctional Health Care Services. Hartley alleged that he had neuropathy and had previously received an egg-crate mattress and pain medication. After a 2019 heroin overdose and a hospital doctor’s recommendation that he resume pain medication, an SVSP psychologist asked medical staff to consider gabapentin for chronic pain. The opinion states that it appeared Bright decided not to prescribe gabapentin, although the timing and reasons were unclear. Hartley also alleged that Bright ultimately denied his 2020 request for another egg-crate mattress.

Screening and Claims

Because Hartley sought relief from governmental defendants, the court screened the Second Amended Complaint under 28 U.S.C. § 1915A. Screening requires the court to 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 stated that pleadings filed without a lawyer must be read liberally.

As to California Correctional Health Care Services, the court explained that an entity may be liable under § 1983 when an unconstitutional policy or practice caused the violation. The court found that Hartley did not allege that the denial of the mattress and pain-medication requests resulted from a policy or practice of that entity. Instead, he repeatedly alleged that Bright made the decisions. The court therefore concluded that Hartley’s claims failed as to California Correctional Health Care Services.

As to Bright, the court applied the Eighth Amendment standard for deliberate indifference to serious medical needs. That standard requires a sufficiently serious medical need and a sufficiently culpable response. The official must know of a substantial risk of serious harm and disregard that risk by failing to take reasonable steps to address it.

The court concluded that Hartley alleged that he requested an egg-crate mattress and pain medication for neuropathy, that Bright denied those requests, and that other doctors considered the treatments appropriate. Read liberally, those allegations stated a cognizable Eighth Amendment claim that Bright’s decisions were medically unacceptable under the circumstances. This was a screening determination allowing the claim to proceed, not a final decision that Bright violated the Constitution.

Rulings and Case Status

The court ordered service of the Second Amended Complaint on Bright through the California Department of Corrections and Rehabilitation’s electronic service program. The order set procedures for waiver of service, service through the United States Marshals Service if necessary, discovery, and later dispositive motions.

The court denied Hartley’s second motion for appointment of volunteer counsel without prejudice to possible appointment later. It found that he had not identified exceptional circumstances and noted that his Eighth Amendment claim did not appear particularly complex. The court stated that it could consider appointing counsel later if the claim survived summary judgment and settlement negotiations.

The order’s title states that the court also denied Hartley’s motion to proceed without paying fees on appeal. The provided opinion text does not include the reasoning for that ruling. The clerk was directed to update the caption so that only Bright remained as a defendant. Judge P. Casey Pitts signed the order on December 4, 2025.