Saddozai v. Bolanos

Background

Shikeb Saddozai, a state prisoner proceeding without a lawyer, filed a civil-rights lawsuit under 42 U.S.C. § 1983. The court previously found that his amended complaint stated a valid claim that David Lomu and Zachary Copeland were deliberately indifferent to his serious medical needs, in violation of the Eighth Amendment, while he was detained at the San Mateo County Jail’s Maguire Correctional Facility.

Saddozai described two incidents. He said that on April 19, 2016, Lomu ignored his reports of severe abdominal pain and vomiting blood, disabled his cell’s emergency intercom monitor, and delayed calling for emergency help. He was eventually taken to a hospital, where he was diagnosed with kidney stones. Lomu gave a different account, stating that he promptly contacted medical staff, that a nurse evaluated Saddozai several times, and that Saddozai was transported to the hospital after medical staff decided transportation was appropriate.

Saddozai also said that on June 11 and 12, 2016, Copeland refused to call medical personnel despite complaints of abdominal pain and chronic constipation. Defendants relied on medical records showing that a nurse practitioner evaluated Saddozai on June 11, that he received medication, and that additional treatment was ordered after a doctor in the emergency department was contacted.

Summary-judgment standard

The defendants moved for summary judgment, arguing that no genuine dispute of material fact existed and that they were entitled to qualified immunity. Summary judgment is appropriate when the evidence would not allow a reasonable jury to decide for the opposing party. The court must view the evidence in the light most favorable to that party but does not decide witness credibility at this stage.

Eighth Amendment claim against Lomu

The court concluded that the evidence did not create a genuine factual dispute about Lomu’s conduct. According to the evidence the court relied on, Lomu notified medical staff after completing his inspection, responded to Saddozai’s continuing complaints, and remained involved while nurses evaluated Saddozai and arranged hospital transportation. The court found no evidence that Lomu knew of a substantial risk of serious harm and deliberately disregarded it.

The court also rejected Saddozai’s arguments that Lomu should have called paramedics sooner, that the removal of Saddozai’s cellmate created a material factual dispute, and that Lomu caused an unreasonable delay. It found that medical personnel made the treatment decisions and that Saddozai had not shown Lomu was responsible for any delay. The court therefore held that Lomu was entitled to summary judgment on the claim.

Eighth Amendment claim against Copeland

The court determined that Copeland was also entitled to summary judgment. It held that Copeland’s requests for admissions were deemed admitted under Federal Rule of Civil Procedure 36 because Saddozai did not respond to them or seek to withdraw or amend them. Among other things, the admissions stated that Copeland promptly forwarded Saddozai’s request for medical attention, that Copeland’s response was not deliberately indifferent, and that the alleged delay did not cause further injury.

The court also relied on the medical records showing that Saddozai was seen by medical staff twice on June 11 and received treatment. It found Saddozai’s allegations too vague or immaterial to create a genuine dispute of material fact. The court concluded that directing Saddozai’s complaints to onsite medical personnel, rather than calling paramedics, reflected at most a disagreement about the proper course of treatment and did not establish deliberate indifference.

Disposition

The court granted Defendants David Lomu and Zachary Copeland’s motion for summary judgment. The court dismissed the Eighth Amendment claims against them with prejudice and stated that the order terminated Docket No. 46. Because it found no constitutional violation, the court stated that it was unnecessary to address the defendants’ qualified-immunity argument.