Hill v. Tyler

Background

Cymeyon Hill filed a civil-rights complaint under 42 U.S.C. § 1983 while in custody at Salinas Valley State Prison. He represented himself. The defendants were psychiatrists M. Tyler and G. Ramos, physician M. Sing, and Acting Warden M. B. Atchley. Hill sought injunctive relief and punitive damages.

Hill alleged that on May 1, 2020, Tyler placed him on the psychiatric medication Zyprexa and told him that refusing it could lead to a court-issued Keyhea order. Hill said he then experienced chest pains, a severe headache, stomach pain, and balance problems. He alleged that Tyler refused to take him off the medication and transferred his care to Ramos. Hill further alleged that Ramos refused his request to stop taking Zyprexa, said she did not care, and again referred to a possible Keyhea order. Hill alleged that Sing repeatedly denied his requests for medical attention.

Screening and Claims

Because Hill sought relief from government employees while in custody, 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 barred because a defendant is immune from monetary relief.

The court explained that deliberate indifference to a serious medical need can violate the Eighth Amendment’s ban on cruel and unusual punishment. The court said a claim requires an objectively serious deprivation and deliberate indifference by the official. Construing Hill’s allegations liberally, the court found a cognizable deliberate-indifference claim against Tyler, Ramos, and Sing. “Cognizable” means the claim was sufficient to proceed past this initial screening; the order did not decide whether Hill will ultimately prove the claim.

The court dismissed Hill’s supervisory-liability claim against Atchley. The complaint did not allege facts showing that Atchley personally violated Hill’s federal rights. The court explained that a supervisor is not automatically liable under § 1983 merely because subordinates allegedly violated someone’s rights; liability generally requires participation in or direction of the violation, knowledge of it and failure to prevent it, or implementation of a policy that caused the violation. The order did not state that this dismissal was with or without prejudice.

Referral, Service, and Case Procedures

The court referred the action to the Northern District of California’s Pro Se Prisoner Mediation Program and directed Magistrate Judge Robert M. Illman to arrange settlement conferences, ordinarily within 120 days of the order or as soon as his calendar permitted. The court ordered service on Tyler, Ramos, and Sing through the California Department of Corrections and Rehabilitation’s electronic-service process, with formal service through the United States Marshals Service if necessary.

The defendants were ordered to answer under the Federal Rules of Civil Procedure. The order established deadlines for possible dispositive motions, Hill’s opposition, and any reply. It also permitted discovery under the federal rules and granted the defendants permission to depose Hill and other necessary witnesses confined in prison. The court separately stated that Hill’s motion to proceed without paying the filing fee would be addressed in another order.

Disposition

The complaint stated a cognizable Eighth Amendment deliberate-indifference claim against Tyler, Ramos, and Sing. Hill’s supervisory-liability claim against Atchley was dismissed. The action was referred to the prisoner mediation program, and the remaining defendants were to be served.