Quarles v. County of Contra Costa

Background

Christopher Quarles, an inmate at the Contra Costa County Jail, filed a self-represented civil-rights complaint under 42 U.S.C. § 1983 against the County of Contra Costa. The court stated that Quarles’s application to proceed without paying the filing fee was granted in a separate order.

Because Quarles sought relief from a governmental entity, the court conducted the preliminary prisoner-complaint screening required by 28 U.S.C. § 1915A. Under that screening rule, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also explained that self-represented pleadings are read liberally, but a complaint still must include enough factual allegations to make a claim plausible rather than merely speculative.

Claim and analysis

Quarles’s only allegation was that he did not receive adequate medical care while in custody. The court explained that a pretrial detainee’s medical-care claim arises under the Fourteenth Amendment and is evaluated under an objective deliberate-indifference standard.

The court described four elements for a medical-care claim against an individual defendant: the defendant intentionally decided the conditions of confinement; those conditions created a substantial risk of serious harm; the defendant failed to take reasonable available measures even though the high risk should have been apparent; and that failure caused the plaintiff’s injuries. To state a claim, Quarles needed to allege facts about his medical needs and the care he did or did not receive that could plausibly establish those elements. The court found that he had not done so.

The court also held that, to proceed against Contra Costa County, Quarles had to allege facts plausibly showing that a County custom or policy caused the constitutional violation. The complaint alleged no such custom or policy.

Ruling

Judge Susan van Keulen ordered that the complaint be dismissed with leave to amend. Quarles was ordered to file an amended complaint within 28 days of the order’s filing date. The amended complaint had to use the required caption and civil case number and include the words “COURT-ORDERED FIRST AMENDED COMPLAINT” on its first page.

The order explained that an amended complaint completely replaces the original, so Quarles could not incorporate the original complaint by reference and had to include all claims he wished to pursue in the amended filing. The court warned that failure to amend in the required time and manner could result in a report and recommendation that the action be dismissed with prejudice. The order also stated that failure to prosecute the case or comply with court orders could result in dismissal under Federal Rule of Civil Procedure 41(b).