Chapman v. Richardson

Background

Marcel E. Chapman, an inmate at Maguire Correctional Facility, filed a self-represented lawsuit under 42 U.S.C. § 1983. He alleged that San Mateo County, San Mateo County Sheriff’s Office sergeant Doug Richardson, and San Mateo Correctional Health Services nurse Amanda Anguelouch were deliberately indifferent to his serious medical needs in violation of the Eighth Amendment.

Chapman alleged that on December 7, 2021, Richardson and Anguelouch deprived him of medically necessary footwear under a county policy requiring inmates to wear jail sandals. Chapman had previously experienced a broken toe and alleged that resulting nerve damage caused loss of feeling in three toes on his right foot and caused his foot to drag without his knowledge. A 2019 memorandum authorized him to have medical-issued shoes while in custody, but the memorandum did not state the medical reason or type of shoe authorized.

On December 7, 2021, Richardson saw Chapman wearing diabetic shoes while Chapman was leaving his housing unit for transportation to court. Richardson required him to change into jail sandals. Richardson later reviewed Chapman’s records and asked Anguelouch to determine whether Chapman had a medical need for alternative footwear. Anguelouch reviewed the records, examined Chapman, observed a normal gait and no visible toe deformity, and concluded that he did not need diabetic shoes. Chapman refused to complete the rest of the physical examination and refused a blood test for diabetes. Anguelouch discontinued the authorization, and Richardson later directed Chapman to surrender the alternative footwear.

Other motions

Chapman requested appointed counsel, a temporary restraining order or protective order, and additional time to oppose defendants’ summary judgment motion.

The court denied the request for appointed counsel because it found no exceptional circumstances. The court said the legal issues were not complex, Chapman had adequately presented his claims, and he did not have a likelihood of success on the merits.

The court denied the request for a temporary restraining order as moot because it was granting summary judgment for defendants. The court also said the requested order concerned alleged retaliation and interference with the litigation, claims that were not included in the complaint. The court denied the request for an extension of time as moot because Chapman had already filed his opposition and the motion was fully briefed.

Summary judgment standard

Summary judgment is appropriate when the record shows no genuine dispute about a fact that could affect the result and the moving party is entitled to judgment under the law. The court must view the evidence and reasonable inferences in the light most favorable to the party opposing the motion, but that party must identify specific evidence showing a real issue for trial.

Eighth Amendment analysis

To prove deliberate indifference to serious medical needs, a prisoner must show both a serious medical need and that the defendant knowingly disregarded a substantial risk of serious harm. A difference between a prisoner’s medical preference and a medically acceptable treatment decision generally does not establish deliberate indifference.

The court granted summary judgment for Richardson and Anguelouch. Even assuming for purposes of the motion that Chapman had nerve damage, numbness, foot dragging, and a prior medical determination that alternative footwear was necessary, the court found no evidence that he still required that footwear on December 7, 2021. His records did not show a chronic condition requiring alternative shoes, Richardson observed him walking normally without obvious pain or discomfort in jail sandals, and Anguelouch’s examination showed a normal gait and no visible deformity. The court found Anguelouch’s decision medically acceptable and characterized the record as, at most, showing two medically acceptable opinions about treatment.

The court also found no evidence that Richardson knew requiring jail sandals during Chapman’s approximately eight-hour court trip created a substantial risk of serious harm. At the time, Richardson knew Chapman claimed to have a prescription, observed no abnormal gait or obvious discomfort, did not know Chapman to have a chronic medical condition, and was applying the general rule requiring jail sandals off the housing unit. The court likewise found no evidence that Anguelouch knew discontinuing the footwear authorization created a substantial risk of serious harm.

County liability

The court granted summary judgment for San Mateo County. Under the rule governing municipal liability, a county may be liable under § 1983 when an official policy, longstanding practice, custom, or final policymaker’s decision causes a constitutional violation. The court found that Chapman acknowledged the county’s footwear policy contained an exception for medically prescribed alternative shoes. Therefore, there was no blanket policy requiring all inmates to wear jail sandals regardless of medical need, and the court had found no underlying constitutional violation.

Attempted additional claims

Chapman also raised arguments concerning disclosure of his medical information and retaliation for filing a grievance. The court treated these arguments as an attempt to amend the complaint and denied that request. It stated that the privacy statute identified in the opinion did not create a private cause of action. It also found that the retaliation allegations had been known to Chapman from the beginning, that he had not previously sought permission to add them, and that amendment at that stage would require reopening discovery and delay disposition of the case.

Disposition

The court denied Chapman’s request for a temporary restraining order, denied his request for an extension of time, and granted defendants’ motion for summary judgment. The court also had denied Chapman’s request for appointed counsel. It directed the clerk to enter judgment for defendants against Chapman and close the case. Because the court found no constitutional violation, it did not conduct a further qualified-immunity analysis.