Rangel v. Williams
- Jacquelyn Corley
- 3:21-cv-00278
- U.S. District Court · Northern District of California
- 4
In Rangel v. Williams, Judge Corley ordered service of Jonathan Rangel’s federal civil-rights complaint after screening found his medical-care claim legally cognizable.
Jonathan Rangel and the four defendants—Vitella Williams, Augusto Pascual, Duc Nguyen, and Gregory Padilla—are affected. The order allows Rangel’s medical-care claim to proceed to service and requires the defendants to respond.
What happened
Jonathan Rangel, a California prisoner representing himself, sued officials at Salinas Valley State Prison under a federal civil-rights law. He alleged that Nurses Vitella Williams and Augusto Pascual, Dr. Duc Nguyen, and Gregory Padilla caused delays in treatment for his broken finger.
The court said the alleged 45-day delay in obtaining an x-ray and 60-day delay in receiving surgery could support a claim that the defendants knowingly disregarded serious medical needs, violating the Eighth Amendment.
The court ordered the complaint served on the four defendants and directed them to respond and file any dispositive motion according to the schedule. Judge Jacquelyn Scott Corley issued the order.
The detailed version
- Rangel v. Williams · No. 3:21-cv-00278
- Jacquelyn Corley
- Feb. 5, 2021
Background
Jonathan Rangel, identified as a California prisoner, filed a civil-rights complaint without a lawyer under 42 U.S.C. § 1983. He sued Registered Nurses Vitella Williams and Augusto Pascual, Dr. Duc Nguyen, and Chief Executive Officer Gregory Padilla, all identified in the order as officials at Salinas Valley State Prison. The opinion states that Rangel’s application to proceed without prepaying filing fees was granted in a separate order.
Screening and claim
Because Rangel was a prisoner suing government officials, the court screened the complaint under the federal prisoner-screening statute. The court had to identify claims that could proceed and dismiss claims that were legally insufficient, frivolous, malicious, sought money from an immune defendant, or otherwise failed to state a claim.
Rangel alleged that the defendants caused him to wait 45 days for an x-ray of his broken finger and 60 days for surgery. The court concluded that, when read liberally, these allegations stated a legally cognizable claim for deliberate indifference to serious medical needs in violation of the Eighth Amendment. Deliberate indifference means knowingly disregarding a serious medical need. The order did not make a final determination that the defendants violated Rangel’s rights; it determined that the claim could proceed beyond screening.
Ruling and next steps
The court ordered the Clerk to issue summonses and related documents and directed the United States Marshal to serve the complaint and order on Williams, Pascual, Nguyen, and Padilla without prepayment of fees. The defendants were ordered to file jurisdiction-consent forms and answers.
The court also directed the defendants to file a motion for summary judgment or another dispositive motion within 91 days of the order, unless they informed the court that summary judgment could not resolve the case. Rangel’s opposition, if any, would be due 28 days after the motion was filed, and the defendants’ reply would be due 14 days after the opposition. Discovery could proceed under the Federal Rules of Civil Procedure. The court warned that failing to prosecute the case or comply with orders could result in dismissal for failure to prosecute.
Judge Jacquelyn Scott Corley issued the order of service. The opinion does not state that the court entered judgment on the merits or dismissed any claim.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.