Harris v. Mayeri

Background

David D. Harris, an incarcerated person proceeding without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 against Stephen Mayeri, a psychiatrist at Salinas Valley State Prison. Harris alleged that he had a long history of mental illness, including auditory hallucinations that sometimes made him want to kill himself. According to the complaint, Mayeri knew Harris was a danger to himself but petitioned the treatment team to reduce Harris’s level of care. Harris alleged that the lower level of care could not meet his mental-health needs and that Mayeri’s failure to treat him properly or keep him away from sharp objects allowed him to cut his wrists and hit his head.

Screening and Analysis

Because Harris sought relief as a prisoner from a governmental employee, the court screened the complaint under 28 U.S.C. § 1915A. Screening requires the court to identify claims that may proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant.

The court explained that a claim under Section 1983 requires an alleged violation of a federal right by someone acting under state authority. It further explained that deliberate indifference to a prisoner’s serious medical needs violates the Eighth Amendment. A prisoner must show both a serious medical need and deliberate indifference to that need.

The court concluded that, when read generously, Harris’s allegations that Mayeri knew about and disregarded a risk to Harris’s mental health by moving him to a lower level of care stated a valid Eighth Amendment claim. That claim could proceed against Mayeri in his individual capacity.

The court dismissed the claim for damages against Mayeri in his official capacity without leave to amend because the Eleventh Amendment barred that claim. The court also dismissed Harris’s California constitutional claim because the complaint did not allege compliance with the California Government Claims Act, which requires timely presentation of certain claims before a damages action may be filed.

Disposition and Case Schedule

The court’s conclusion states that the complaint presented a cognizable Section 1983 claim against Mayeri for violating Harris’s Eighth Amendment rights and that all other claims and defendants were dismissed. The clerk was directed to issue a summons, and the United States Marshal was directed to serve Mayeri without requiring advance payment of fees.

The court set deadlines for dispositive motions, Harris’s opposition, and any reply. It also warned Harris about the requirements for opposing a motion for summary judgment, authorized discovery under the Federal Rules of Civil Procedure, and instructed him to keep the court informed of address changes and to comply with court orders. The court allowed Harris 30 days to amend the state-law claim if he could allege that he had timely complied with the California Government Claims Act; the court would then decide whether to require Mayeri to respond to that claim.