Crawford v. Combs

Background

Christopher Lee Crawford, a state prisoner proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983. He alleged that officials at Pelican Bay State Prison were deliberately indifferent to his safety needs after an April 13, 2016 incident. According to the amended complaint, Sergeant Combs and Correctional Officer Spradlin forced Crawford out of his cell while discussing his safety concerns and asked in front of other inmates whether he wanted to be housed in the Special Needs Yard. Crawford also alleged that Correctional Officer Oviatt and Captain M. Townsend participated in efforts to entrap him by questioning him about that housing choice in front of general-population inmates. He sought declaratory relief and money damages.

The court had previously found that Crawford stated a legally cognizable deliberate-indifference claim against Combs, Spradlin, Oviatt, and Townsend. It had dismissed Crawford’s supervisory-liability claim against CDCR Secretary Scott Kernan. The defendants then filed a motion for summary judgment, a motion to file confidential investigatory and medical records under seal, and a motion to stay discovery. Crawford did not file an opposition to the summary-judgment motion after receiving three extensions. Instead, he filed a document seeking a continuance, which the court treated as a motion under Federal Rule of Civil Procedure 56(d).

Reasoning

Rule 56(d) allows a court to postpone or deny summary judgment when the opposing party has not had enough opportunity to obtain evidence needed to respond. The court explained that summary judgment is generally disfavored when relevant evidence remains to be discovered, particularly for confined people representing themselves. Crawford said he could not adequately respond because he had been unable to obtain potentially relevant evidence from the defendants, and the defendants did not oppose his request for additional time.

The court therefore found it proper to allow discovery before Crawford responded to the summary-judgment motion. The order did not determine the merits of Crawford’s allegations or whether the defendants were entitled to judgment after discovery.

Rulings and schedule

The court granted Crawford’s Rule 56(d) motion. It denied without prejudice the defendants’ motion for summary judgment, meaning the defendants may file a renewed motion after discovery. It denied as premature the defendants’ motion to stay discovery, and it denied as moot all remaining pending motions.

The court ordered Crawford to serve discovery requests within 28 days of the order. The defendants were to respond or object within 45 days. After meeting and conferring about any unresolved discovery dispute, Crawford could file a motion to compel within 60 days if necessary. Both sides were required to file status reports within 28 days. The defendants could file a renewed summary-judgment motion within 90 days; Crawford’s opposition would be due 28 days later, and the defendants’ reply would be due 14 days after that. Judge Yvonne Gonzalez Rogers also stated that any motion to compel filed before the parties met and conferred would be denied without prejudice as premature.