Golson v. Narvaez

Background

Jamar Brandon Golson, a California state prisoner, brought claims under 42 U.S.C. § 1983, a federal civil-rights statute. He alleged that correctional officers at Salinas Valley State Prison used excessive force against him during a search on April 23, 2017, and that medical staff were deliberately indifferent to his serious medical needs in treating his shoulder injury. The defendants moved for summary judgment, which asks whether the evidence shows that no genuine dispute of important fact exists and that the moving party is entitled to judgment as a matter of law.

Golson alleged that, after a correctional officer found possible contraband, the officer grabbed his genital area, slammed him against a wall, and jumped on him. He further alleged that other officers then joined in restraining him and worsened his pain. The officers gave a different account, asserting that Golson resisted, kicked an officer, tried to break free, and reached under his body, leading them to use force to restrain and handcuff him. Two candy bars found in Golson’s possession tested positive for heroin, and he later pleaded no contest to state charges involving possession of a controlled substance and delaying a peace officer.

Golson’s medical-care claims concerned the denial of requests for an orthopedic specialist and a delay in renewing his pain medication. The medical defendants presented evidence that his grievances did not identify the medical staff members or describe their actions in connection with the allegedly inadequate care.

Medical-Care Claims and Exhaustion

The Prison Litigation Reform Act requires a prisoner to complete available administrative remedies before bringing a federal action about prison conditions. The court found that Golson filed two medical grievances related to his shoulder injury, but the initial grievances did not complain about the actions of Erguiza, Bright, or Kumar. One grievance mentioned Erguiza only in connection with confirming that Golson’s prescription had expired; the other did not name any of the three medical defendants and referred only to an unnamed doctor’s denial of a specialist referral.

The court also rejected Golson’s general assertion that he had exhausted his remedies. It concluded that he had not shown that he completed the required grievance process or that the process was unavailable. The court therefore granted defendants’ motion for summary judgment as to the claims against Erguiza, Bright, and Kumar.

Excessive-Force Claims

For an Eighth Amendment excessive-force claim, the question is whether prison officials used force in a good-faith effort to maintain or restore discipline, or instead used force maliciously and sadistically to cause harm. The court found that Golson and the officers presented two directly conflicting versions of the incident. If Golson’s account were accepted, a jury could find that the officers used force to cause harm rather than to restore order. If the officers’ account were accepted, a jury could find that they used force in response to Golson’s resistance.

Because this factual dispute could affect the outcome, the court found a triable issue and denied defendants’ motion for summary judgment as to the excessive-force claims against Narvaez, Alvarado, Akins, and Aranda.

Qualified Immunity

Qualified immunity can protect government officials from civil damages when their conduct did not violate a clearly established statutory or constitutional right that a reasonable official would have understood. Viewing the facts in the light most favorable to Golson, the court concluded that the alleged conduct—touching Golson’s genitals, throwing him against a wall, jumping on him, and piling on top of him while he was face down—would violate a constitutional right, and that a reasonable officer would have understood the conduct to be unlawful in the circumstances described. The court therefore ruled that the correctional officers were not entitled to qualified immunity.

Disposition

The court stated that defendants’ motion for summary judgment was granted in part and denied in part: it was granted as to the medical-care claims against Erguiza, Bright, and Kumar, and denied as to the excessive-force claims against Narvaez, Alvarado, Akins, and Aranda. The court referred the remaining excessive-force claims to Judge Robert Illman for settlement and stayed the action until further order. The order also warned that failing to attend scheduled settlement conferences could lead to dismissal of the action for failure to prosecute.