Jacobson v. Contra Costa County

Background

Nicholas Jacobson entered Sutter Health Memorial Hospital in June 2017 after suffering a lumbar spinal fracture in a car accident. He was held as a pretrial detainee at the Martinez Detention Facility from June 21 through July 5, 2017, and later returned there in January 2018 after treatment at other hospitals.

Jacobson’s lawsuit alleged that defendants violated the Fourteenth Amendment, the Americans with Disabilities Act, the Rehabilitation Act, and standards of care by providing inadequate medical care during his 2017 detention. The opinion states that the lawsuit was filed in April 2019.

Summary-judgment motion

Jacobson moved under Federal Rule of Civil Procedure 56 for summary judgment on defendants’ affirmative defense that he had failed to exhaust available administrative remedies. The Prison Litigation Reform Act requires a prisoner to complete available administrative remedies before bringing an action concerning prison conditions under 42 U.S.C. § 1983 or another federal law. The court explained that proper exhaustion requires compliance with applicable deadlines and procedural rules.

Defendants had the burden to show both that an administrative remedy was available and that Jacobson did not exhaust it. Jacobson then had the burden of producing evidence that something specific to his case made the generally available remedy effectively unavailable.

Disputed facts about exhaustion

The Martinez Detention Facility’s grievance policy required formal grievances to be submitted within 48 hours of the incident or condition. The parties disputed whether the facility notified Jacobson about the grievance and appeal procedures. Jacobson argued that the facility did not provide him with a copy of its grievance policies. Defendants responded that inmates, including Jacobson, were informed about the procedures through an orientation video shown upon admission.

The parties also disputed whether the grievance process remained available to Jacobson after the 48-hour period. Jacobson argued that his injuries prevented him from exhausting administrative remedies during his 2017 detention. Defendants argued that he could have filed grievances when he returned to the facility in 2018, but that he instead waited until February 2019. The court concluded that a jury could resolve these disputed issues in either direction.

Ruling

The court held that genuine disputes of material fact prevented summary judgment on the exhaustion defense. It therefore denied Jacobson’s motion for summary judgment. It also denied defendants’ request for an order granting summary judgment in their favor without a separate motion. The court did not decide in this order whether Jacobson ultimately received inadequate medical care or whether defendants violated the laws he invoked.

Jacobson objected to declarations and exhibits submitted by defendants. The court overruled those objections as moot because considering the materials would not change the outcome of the order.