Bratton v. Broomfield

Background

Ronald W. Bratton, a California inmate proceeding without a lawyer, sued prison officials and staff under 42 U.S.C. § 1983. The operative pleading was his second amended complaint. The court had previously found that, liberally construed, it stated a cognizable Eighth Amendment claim against S. Albritton, Dr. S. Garrigan, Dr. Sandler, A. Maxfield, and N. Smith.

Bratton alleged that he had chronic lymphocytic leukemia, thalassemia, and hypertension. He said his oncologist recommended single-cell housing to protect him from contagious diseases and immune-compromising viruses. His request for a reasonable accommodation was denied in 2017. After COVID-19 appeared at San Quentin State Prison, he submitted another single-cell request on April 9, 2020, which was also denied. He alleged that infected inmates were later transferred to the prison, that an infected inmate was moved into his cell, and that he subsequently tested positive for COVID-19. In his opposition to dismissal, he also described high blood pressure, slowed thinking, general malaise, and weakened legs.

Motion to Dismiss

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that the second amended complaint failed to state an Eighth Amendment deliberate-indifference claim and that they were protected by qualified immunity. A Rule 12(b)(6) motion tests whether the complaint alleges enough facts to state a legally plausible claim; it does not decide whether the plaintiff will ultimately prevail.

The court found that the second amended complaint did not adequately allege that the defendants knew of an excessive risk to Bratton when they denied his single-cell request. It also found that the complaint lacked sufficient allegations of injury and causation. The court noted that Bratton’s opposition relied on new allegations and evidence rather than defending the allegations in the second amended complaint. Accordingly, the court granted the motion to dismiss the second amended complaint for failure to state a claim.

The court nevertheless granted leave to amend. Considering the new allegations and evidence in the light most favorable to Bratton, the court found that he might be able to cure the pleading deficiencies. The court said that the allegation that COVID-19 had been found at the prison before the renewed request could support an inference that the defendants knew of a serious risk that had not previously existed. The allegation that an infected inmate was moved into Bratton’s cell around the time infected inmates arrived at the prison could also plausibly support causation and injury. The court did not find that evidence showing Bratton was doing well with respect to his cancer in September 2020, or that his COVID-19 infection had later resolved, conclusively showed that he had not suffered earlier harm.

Qualified Immunity

Qualified immunity is a defense that can protect government officials from civil damages unless their conduct violated a constitutional right that was clearly established at the time. The defendants argued that no clearly established law required single-cell housing for an inmate facing a generalized infection risk during the pandemic.

The court denied the qualified-immunity portion of the motion without prejudice to the defendants raising the defense later. It reasoned that Bratton could allege enough facts in another amended complaint to state an Eighth Amendment claim. The court also concluded that existing precedent clearly established a person in custody’s right to protection from heightened exposure to a serious communicable disease, and that the defendants could not establish at this stage that they lacked notice their conduct might violate the Constitution.

Official-Capacity Damages Claims

Bratton sought monetary relief against the defendants in both their individual and official capacities. The court held that the Eleventh Amendment barred damages claims against the defendants in their official capacities. It granted the defendants’ motion to dismiss those claims and dismissed them with prejudice because the jurisdictional bar could not be cured by further amendment.

Preliminary Injunction and Other Motion

Bratton sought a preliminary injunction, an extraordinary remedy requiring a showing that he was likely to succeed, likely to suffer irreparable harm without relief, and supported by the balance of equities and public interest. Because the second amended complaint had been dismissed with leave to amend, the court found that he had not shown a likelihood of success at that stage. The court denied the motion for injunctive relief without prejudice.

The court denied the defendants’ motion for an extension of time as moot.

Order

The court ordered Bratton to file a third amended complaint within 28 days. That complaint would replace the earlier pleadings, and claims or defendants omitted from it would no longer remain in the case. The court stated that failure to file the required amended complaint on time would result in dismissal with prejudice of the action for failure to state a claim, without further notice.