Battersby v. Lien

Background

Erick Allen 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. He alleged that while detained at Humboldt County Correctional Facility from about October 2017 through about December 2019, he developed Raynaud’s syndrome and needed extra blankets to keep warm.

Battersby alleged that medical staff delayed or failed to arrange treatment, failed to ensure that doctors’ blanket orders reached custody staff, and did not prescribe medication. He also alleged that correctional staff denied his requests for an extra blanket, disciplined him for remaining under blankets during the day, and enforced the jail’s bed-and-dress rule despite his reported medical condition. He requested $1.2 million in damages and an injunction ending that rule.

Amendment and screening

The court granted Battersby’s motion to file a third amended complaint because the defendants had not filed a dispositive motion against it and appeared unlikely to be prejudiced by the amendment. The court then screened the complaint under the federal prisoner-screening statutes, which require the court to identify claims that may proceed and dismiss claims that are frivolous, fail to state a claim, or seek unavailable relief.

The court concluded that, read generously, the complaint stated cognizable claims for monetary damages under the Fourteenth Amendment against the named medical and correctional defendants. The court reasoned that Battersby alleged pain from Raynaud’s syndrome and alleged facts that could show deliberate indifference to serious medical needs.

The court identified potentially cognizable claims against Nurse Iver Lien, Dr. Ziegler, Nurses Edmondson and Santuccio, Captain Christian, Corporals Jackson, Twitchel, and Freese, and Correctional Officer Coleman. The alleged conduct included delayed medical attention, failure to implement medical orders, failure to prescribe medication, and disciplinary actions or enforcement of the blanket rule despite the alleged medical need.

The court treated Battersby’s claims as arising under the Fourteenth Amendment because he appeared to allege that he was a pretrial detainee during the relevant period. The court did not decide that the defendants were liable; it decided only that the allegations were sufficient to proceed past screening.

The court dismissed the request for an injunction as moot. Battersby had been transferred from Humboldt County Correctional Facility, and the court found no reasonable expectation or demonstrated probability that he would return to the facility and again face the challenged rule.

Discovery motions

The court granted Battersby’s first motion to compel and ordered the defendants to provide the relevant portion of a medical manual. It denied the motion seeking an order preserving body-camera footage because the defendants had already preserved and produced relevant footage. It also denied another motion to compel because the materials at issue had already been produced.

The court directed the clerk to terminate Docket No. 87 because Battersby appeared to have filed that discovery request with the court by mistake rather than sending it to the defendants. The conclusion states that the other discovery-related motions were denied for the reasons stated above.

Disposition

The third amended complaint proceeds on the cognizable damages claims against the named medical and correctional defendants. Nurse Santuccio had to be served, after which the court would set a schedule for motions that could dispose of the case. The order also granted the first discovery-related motion and denied the other discovery-related motions as described above.