Steward v. Stevenson

Background

Jason J. Steward brought a civil-rights action under 42 U.S.C. § 1983 concerning prison employees’ conduct after a January 8, 2020 fight with another inmate at Salinas Valley State Prison. The court had screened Steward’s First Amended Complaint and found one cognizable claim: deliberate indifference to a serious medical need. Steward chose to proceed only on that medical-care claim; the court had dismissed his other claims with leave to amend.

The evidence submitted by the defendants showed that medical staff examined Steward about eleven minutes after the fight and performed several follow-up examinations. The evidence also showed that Steward did not report rib or back pain to the officers who responded, the officers who escorted him, the medical staff who examined him that day, or Defendant Baagala. On January 9, 2020, Steward submitted a medical slip stating that he thought he might have injured his ribs, back, and ring finger.

Steward did not oppose the defendants’ summary-judgment motion. Because his complaint was not verified and he submitted no opposing evidence, the court treated the defendants’ evidence as undisputed for purposes of the motion.

Exhaustion ruling

The Prison Litigation Reform Act requires prisoners to exhaust available administrative remedies before bringing a federal civil-rights action about prison conditions. The defendants argued that Steward had not properly exhausted his deliberate-indifference claim against Mariscal, Benitez, Futch, Grady, Mendez, Sandoval, Barroso, and Lopez.

The court agreed. Steward’s grievances did not identify Mariscal, Benitez, Futch, Grady, Mendez, Sandoval, or Barroso in connection with the January 8 incident. Although one grievance accused Lopez of using excessive force and stated that officers should have summoned medical assistance, it did not claim that Lopez was deliberately indifferent to Steward’s medical needs. The court therefore concluded that Steward failed to exhaust his medical-care claim against all eight defendants and held that those defendants were entitled to summary judgment.

Merits ruling

For Baagala, Soto, and Stevenson, the court considered whether the evidence established deliberate indifference. An Eighth Amendment medical-care claim requires proof of a serious medical need and proof that the defendant knew of a substantial risk of serious harm but disregarded it by failing to take reasonable measures.

As to Soto and Stevenson, the court found undisputed evidence that they summoned medical assistance. Because medical staff were treating or evaluating Steward, the custodial defendants could reasonably rely on the medical staff’s actions.

As to Baagala, a licensed vocational nurse, the court found no evidence that Steward told her about rib or back pain. Baagala documented that Steward said he did not feel good, recorded pepper-spray exposure and redness on his back, performed follow-up examinations, notified her supervisor, and instructed Steward to seek additional care if his condition changed. The court concluded that the evidence did not show Baagala knew Steward had suffered a serious injury or failed to take reasonable steps to address it.

The court also noted that Steward’s January 9 medical slip was reviewed by another medical staff member and contained no evidence that Baagala learned about it. Because Steward provided no evidence creating a genuine dispute of material fact, the court held that his deliberate-indifference claim failed on the merits as to Baagala, Soto, and Stevenson.

Disposition

Judge Edward Chen granted the defendants’ motion for summary judgment. The defendants were awarded judgment in their favor, and the Clerk was directed to close the file. The Clerk was also directed to terminate Docket No. 44, which concerned a substitution of defense counsel and had been incorrectly docketed as a motion. The order disposed of Docket Nos. 39 and 44.