Martin v. Muniz
- Beth Freeman
- 5:17-cv-01690
- U.S. District Court · Northern District of California
- 9
In Martin v. Muniz, Judge Freeman denied Martin’s reconsideration motion and related requests after summary judgment rejected his medical-care claims.
George Martin and the prison officials he sued; the order denied Martin’s requests and left the prior summary judgment in place.
What happened
Martin v. Muniz is a civil-rights case brought by George Martin, a California inmate, against prison officials under a federal civil-rights law. The court had previously granted the officials’ motion for summary judgment on Martin’s claim that they were deliberately indifferent to his serious medical needs.
Martin asked the court to reconsider that decision under Rules 59(e) and 60(b) of the Federal Rules of Civil Procedure. He argued that the court was not impartial, that Dr. Bright’s declaration contained false statements, and that his medical records supported his claims about medication, pain, and surgery.
Judge Beth Labson Freeman denied the reconsideration motion under both rules, finding no qualifying legal change, new evidence, mistake, or fraud. The court also denied as moot Martin’s requests for more time to respond and to serve the reconsideration motion on defense counsel.
The detailed version
- Martin v. Muniz · No. 5:17-cv-01690
- Beth Freeman
- May 25, 2021
Background
George Martin, identified in the order as a California inmate, filed a civil-rights action under 42 U.S.C. § 1983 against officials at Salinas Valley State Prison. The case concerned treatment of chronic pain related to longstanding neck and back injuries and the alleged failure to provide corrective surgery.
Martin’s allegations included claims about incorrect blood-pressure medication, being labeled a noncompliant patient, changes to his pain medication, cancellation of extended-release morphine, and denial of pain medication, a computed tomography scan, and surgery during 2016 and 2017. The court previously granted the defendants’ motion for summary judgment on Martin’s Eighth Amendment claim alleging deliberate indifference to serious medical needs. The court concluded that there was no genuine dispute of material fact supporting those claims.
Motion for Reconsideration
Martin moved for reconsideration under Federal Rules of Civil Procedure 59(e) and 60(b)(1) through (6). Rule 59(e) permits a court to alter or amend a judgment in limited circumstances, such as a qualifying change in law, newly discovered evidence, or clear error. Rule 60(b) provides other limited grounds for relief from a judgment, including mistake, newly discovered evidence, fraud, a void judgment, satisfaction of the judgment, or another extraordinary reason justifying relief.
Martin argued that the court had not been impartial and that Dr. Bright’s declaration included “perjured” statements. He also repeated arguments about a surgery in 2006 and submitted medical records concerning his medication and need for surgery.
Court’s Analysis
The court found no basis for relief under Rule 59(e). Martin identified no intervening change in controlling law. The court also found that most of the submitted medical records had been available before the summary-judgment ruling and therefore were not newly discovered evidence for purposes of reconsideration. The court determined that other information Martin submitted was not relevant to the issues previously resolved.
The court noted that a 2011 letter concerning a class-action inquiry did not establish that officials improperly denied surgery in 2016 and 2017. The court had previously relied on a January 2017 report by Dr. Ramberg stating that surgery was not a viable option for relieving Martin’s chronic pain. The other medical reports Martin cited were from 2007 and 2008, years before the alleged denial of surgery.
The court also rejected Martin’s assertions that Dr. Bright’s declaration was fraudulent. It found that Dr. Bright summarized medical records attached to his declaration and that Martin disagreed with the observations in the records but did not show that Dr. Bright mischaracterized them. The court further found that alleged inconsistencies about an incident and statements concerning Martin’s behavior did not affect the outcome because other evidence addressed those matters. The court concluded that Martin had not shown fraud that harmed the integrity of the judicial process or any other extraordinary reason for relief under Rule 60(b).
Disposition
The court denied Martin’s motion for reconsideration under Rule 59(e) and Rule 60(b). It also denied as moot Martin’s request for an extension of time to respond to the court’s order and his request to have the reconsideration motion served on defense counsel. The order terminated Docket Nos. 173, 174, and 175.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.