Battersby v. Lien

Background

Erick Battersby, who was incarcerated at Pelican Bay State Prison when the order was issued, filed this self-represented civil-rights action under 42 U.S.C. § 1983 concerning events at Humboldt County Correctional Facility, where he had previously been detained. He alleged that he developed Raynaud’s syndrome, a condition that made exposure to cold painful and potentially harmful, and that he needed extra blankets to stay warm.

Battersby alleged that medical and correctional staff delayed or failed to provide an extra blanket, prevented him from remaining under blankets during the day, and disciplined him for violating the jail’s bed-and-dress rule. He sought $1.2 million in damages and an injunction—an order requiring officials to stop enforcing the rule.

Amendment and Screening

The court granted Battersby’s motion to file a second amended complaint and screened that complaint under the statutes requiring preliminary review of prisoner complaints. The court concluded that, liberally construed, the complaint stated a Fourteenth Amendment claim for deliberate indifference to medical needs against the named Medical Defendants and Correctional Defendants.

The court identified cognizable claims against Nurse Iver Lien based on alleged inadequate treatment, delay in sending Battersby to a doctor, and acquiescence in the daytime blanket restriction. It identified claims against Dr. Ziegler based on alleged failures to ensure that Battersby received and could use an extra blanket and failure to prescribe medication. It also identified a claim against Nurse Edmondson based on the alleged delay in transmitting Dr. Ziegler’s blanket order.

The court found cognizable claims against Corporal Jackson, Corporal Twitchel, Corporal Freese, and Correctional Officer Coleman based on alleged disciplinary actions related to Battersby’s use of blankets. It also found a claim against Captain Christian based on the alleged creation of the bed-and-dress rule.

The court dismissed Does 1–4 because Battersby’s allegations against them were conclusory and contradicted by more specific allegations indicating that they had performed their duties correctly. The court also ruled that Battersby’s request for an injunction concerning the jail’s rule was moot because he had been transferred to the state prison system and had not shown a reasonable expectation or demonstrated probability that he would return to the Humboldt County facility. The court stated that only the damages claims could be pursued.

Discovery Motions

The court granted Battersby’s request for access to a disc player so that he could review body-camera footage produced by the defendants. The court denied his request for documents concerning other inmates’ medical complaints, administrative appeals, and exemptions from the bed-and-dress rule, finding that the requests were overbroad and implicated third-party privacy interests. The court also denied his request to subpoena the names and addresses of nurses because the claims against Does 1–4 had been dismissed and he therefore did not need to serve them.

The court denied Battersby’s request for blank subpoena forms as unnecessary because the Clerk had already sent him forms. It also denied, to the extent he intended it as a motion to compel, a filing concerning a prior document request because the defendants appeared to have responded and there was nothing to compel.

Disposition and Case Management

The court granted Battersby’s motion to amend and screened the second amended complaint. It ruled that the complaint stated cognizable Fourteenth Amendment damages claims against the named Medical and Correctional Defendants and dismissed Does 1–4 from the action. The court granted the first discovery-related motion and denied the second, third, fourth, and fifth discovery-related motions.

The court ordered defendants to file any dispositive motion by December 2, 2022, set January 6, 2023, for Battersby’s opposition, and set January 20, 2023, for defendants’ reply. It also stated that discovery could proceed under the Federal Rules of Civil Procedure and reminded Battersby of his obligations to serve filings on defense counsel, keep the court informed of address changes, and prosecute the case.