Hopkins v. California Forensic Medical Group

Background

Keith M. Hopkins, a federal prisoner incarcerated at Federal Correctional Institution-Lompoc, filed this civil-rights action while representing himself. He alleged that constitutional violations occurred while he was held as a pretrial federal detainee at Santa Rita Jail from September 2015 to 2018. Hopkins alleged that he has sleep apnea and sought monetary and punitive damages.

The complaint named California Forensic Medical Group (CFMG), CFMG health-care provider Dr. Maria Magat, Alameda County, Alameda County Sheriff Gregory Ahern, and unidentified defendants designated as “Does 1-30.” The claims involved access to and replacement of Hopkins’s continuous positive airway pressure (CPAP) equipment, alleged denial of medical care, a California medical-care statute, and supervisory liability.

Screening standard

Because Hopkins sought relief from governmental entities or officers, the court screened the complaint under 28 U.S.C. § 1915A. At this stage, the court had to identify claims that were legally cognizable and dismiss claims that were frivolous, malicious, failed to state a claim, or sought damages from an immune defendant. To state a claim under 42 U.S.C. § 1983, Hopkins had to allege both a violation of a federal right and action under state law.

Rulings

The court dismissed without prejudice Claims 1 through 5 to the extent they were asserted against CFMG, Alameda County, and Ahern. The court found that Hopkins had not alleged facts showing that those defendants violated his federal rights and appeared to be relying on the conduct of subordinates. The court explained that § 1983 does not impose liability on a supervisor merely because of the supervisor’s responsibility for another person’s conduct. It also found that Hopkins had not alleged a sufficient basis for municipal liability against CFMG or Alameda County beyond that type of supervisory-liability theory.

The court held that Claims 2 and 5, liberally construed, stated cognizable Fourteenth Amendment medical-care claims against Magat, “Jane Does #1 and #2,” and “Doe #3.” Claim 2 concerned Magat’s alleged denial of a request for a sleep-deprivation and CPAP-equipment specialist and the alleged failure of Jane Does #1 and #2 to obtain an escort for CPAP treatment. Claim 5 concerned the alleged denial of a request for a rechargeable CPAP battery. The court also held that Claim 3 stated a cognizable California-law claim against Jane Does #1 and #2 based on the alleged failure to obtain an escort to the outpatient housing unit for CPAP treatment.

The court dismissed without prejudice Hopkins’s claims against the remaining unidentified defendants, “Does 4-30.” It allowed Hopkins an opportunity through discovery to identify Jane Does #1 and #2 and Doe #3. The order states that those three defendants would be dismissed without prejudice if Hopkins did not provide their names by the deadline for a served defendant’s dispositive motion.

Case status and next steps

The court ordered service of the summons, complaint, attachments, and order on Dr. Magat. The surviving claims were to proceed under the stated schedule, including an answer, possible summary-judgment or other dispositive motion, and discovery. The order also required Hopkins to serve his court filings on the defendant or counsel once counsel was designated and to keep the court informed of any address change. The opinion does not resolve the ultimate merits of the surviving claims.