Maldonado v. Passon

Background

Marciaz Maldonado, an inmate at California Substance Abuse Treatment Facility, filed a pro se action under 42 U.S.C. § 1983. He alleged that, while housed at Correctional Training Facility, he slipped on water on June 27, 2022, broke his hand, and fractured his knee. He alleged that Chief Medical Executive Steven Posson and three unidentified healthcare providers were responsible for his medical care and failed to provide treatment or medication. The complaint asserted violations of the Eighth Amendment, the Tort Claims Act, general negligence, and intentional infliction of emotional and physical pain.

The court reviewed the complaint under 28 U.S.C. § 1915A, which requires preliminary screening of a prisoner’s claims against a governmental entity or officer. The court had separately granted Maldonado permission to proceed without paying the filing fee.

Reasons for Dismissal

The court dismissed the complaint with leave to amend for several reasons.

First, the complaint did not link Posson or any Doe defendant to a specific act or failure to act that violated federal or state law. The court explained that anonymous defendants generally cannot be served, although Maldonado could seek to identify them through discovery and then request permission to amend the complaint to name them.

Second, the court held that Posson could not be liable under § 1983 merely because he supervised the Doe defendants or generally oversaw medical care at the facility. The court explained that § 1983 does not impose liability simply because of a supervisory role. A viable supervisory-liability theory would require facts showing, for example, that the supervisor caused the deprivation, failed to train or supervise staff, was responsible for a policy or custom that caused the deprivation, or knew of misconduct and failed to prevent it.

Third, the court found that the complaint did not state a sufficient Eighth Amendment medical-care claim. Such a claim requires facts showing a serious medical need and deliberate indifference—meaning that a defendant knew of a substantial risk of serious harm and failed to take reasonable steps to address it. The court found it unclear what additional care Maldonado required beyond the splint he received for his broken hand and how the defendants unreasonably responded to his medical needs.

The court also noted that the complaint and its attachments contradicted the allegation that Maldonado received no medical care between June 27, 2022, and December 7, 2022. The records indicated that he was sent to an outside hospital for urgent X-rays, had the splint removed, received hand exercises, was scheduled for physical therapy, and apparently was prescribed pain medication.

State-Law Claims

The court declined to screen the remaining claims at that time because they appeared to arise under state law. It stated that deciding whether to exercise supplemental jurisdiction over state-law claims would be premature because there was no operative complaint after the federal claims were dismissed.

Disposition

The court dismissed the complaint with leave to amend. It gave Maldonado 28 days from the date of the order to file an amended complaint addressing the identified deficiencies. The amended complaint had to use the caption and case number specified in the order, include the words “AMENDED COMPLAINT” on its first page, and include all claims and defendants Maldonado wished to pursue. The order stated that failure to file a proper amended complaint within the required time would result in dismissal of the action without further notice.