Stuckey v. California Departmnet of Corrections and Rehabilitation

Background

Andre Kenneth Stuckey filed this civil-rights action under 42 U.S.C. § 1983 without a lawyer and sought monetary and punitive damages. He alleged that, after being placed in Pelican Bay State Prison’s medical isolation unit on May 18, 2020, because of COVID-19 symptoms and possible exposure, prison officials delayed required testing and contact tracing, provided an inadequate quarantine unit, and denied him daily mental-health checkups for 15 days. He asserted claims under the Eighth Amendment and Title II of the Americans with Disabilities Act.

The defendants named in the complaint included the California Department of Corrections and Rehabilitation; its Secretary Ralph Diaz and Director Connie Gipson; California Correctional Health Care Services; Pelican Bay State Prison; several prison administrators, medical personnel, officers, nurses, and John Doe defendants.

Screening and Claims

The court conducted the required preliminary review of a prisoner’s complaint under 28 U.S.C. § 1915A. At this stage, the court must identify claims that may proceed and dismiss claims that are frivolous, fail to state a claim, or seek money from an immune defendant.

The court held that, liberally construed, Stuckey’s allegations stated cognizable Eighth Amendment claims for deliberate indifference to serious medical needs against the remaining named defendants. “Cognizable” means claims that are legally sufficient to proceed past this initial review; the order did not decide whether Stuckey would ultimately prevail.

The court found that Stuckey had not adequately stated a Title II ADA claim against Pelican Bay State Prison because he did not specifically allege that he was an individual with a disability, was otherwise qualified to receive the public entity’s services, or was denied those services because of his disability. The court also stated that California Correctional Health Care Services was not a proper ADA defendant and that claims against it were barred by Eleventh Amendment immunity.

The court found that Stuckey’s equal-protection allegations were conclusory and ambiguous. It further held that Stuckey had not alleged facts showing that Diaz or Gipson personally participated in, directed, or knowingly failed to prevent the alleged violations. Finally, the court permitted the possibility that Stuckey could identify the John Doe defendants through discovery and seek to add them in an amended complaint.

Rulings

The court ordered the following:

- Any ADA claims against California Correctional Health Care Services were dismissed with prejudice. - All remaining claims against California Correctional Health Care Services were dismissed without prejudice. - The equal-protection claim was dismissed without prejudice. - Claims against the named defendants in their official capacities seeking monetary damages were dismissed with prejudice. - The supervisory-liability claims against Diaz and Gipson were dismissed without prejudice. - Claims against John Does #1–3 were dismissed without prejudice. - Stuckey was found to have stated cognizable deliberate-indifference claims against the remaining named defendants.

The court referred the case to the Northern District of California’s Pro Se Prisoner Mediation Program, administered for this matter by Magistrate Judge Robert M. Illman. After the complaint was served on the defendants against whom cognizable claims were alleged, further proceedings were stayed and the clerk was directed to administratively close the case. The order stated that, if the case was not settled, the court would issue a scheduling order for further proceedings.