Campbell v. Callis

Background

Senarble Campbell filed a civil-rights action under 42 U.S.C. § 1983 against correctional officials and staff at Salinas Valley State Prison. He represented himself. Campbell participated in the California Department of Corrections and Rehabilitation’s mental-health system and had previously been kept in a single cell because of disciplinary reports involving threats to kill a cellmate.

In April and May 2018, Campbell was placed in the Administrative Segregation Unit after an alleged battery on a peace officer. During that period, he repeatedly expressed suicidal or homicidal thoughts, broke windows, and engaged in other disruptive conduct. Defendant M. Callis, a contract psychologist who evaluated Campbell during that period, concluded that Campbell was not at acute risk and could return to his housing. Campbell disputed aspects of Callis’s evaluations and alleged that Callis failed to conduct proper suicide-risk assessments and failed to respond appropriately to Campbell’s statements.

At a May 3, 2018 Institutional Classification Committee meeting, defendants Hatton and Aguilera participated, and Callis provided mental-health information. The committee extended Campbell’s placement in administrative segregation and continued his single-cell status. At a June 26, 2018 Unit Classification Committee meeting, defendants Thomas, Godinez, Gamboa, and Swearengin participated. Swearengin recommended double-cell housing, and the committee decided to house Campbell with a cellmate. Campbell told the committee and later submitted forms and grievances stating that he would kill or rape a future cellmate.

On August 2, 2018, after being assigned a cellmate, Campbell assaulted the cellmate with a hotpot and fan and was later placed in administrative segregation. Campbell alleged that the earlier decisions caused or contributed to harm and worsening mental-health problems.

Motions and legal standards

The defendants moved to strike exhibits Campbell submitted with his opposition to summary judgment, arguing that Campbell had not properly authenticated the exhibits or shown that they were unaltered. The court denied that motion. It relied on Ninth Circuit authority requiring courts to construe filings by self-represented prisoners liberally and to focus at the summary-judgment stage on whether the evidence’s contents could be admissible, rather than requiring strict compliance with ordinary evidentiary procedures. The court found that many exhibits were prison records, some had also been submitted by the defendants, and nothing in the record suggested that the exhibits had been altered or could not be admitted at trial.

The defendants also moved for summary judgment. Summary judgment is appropriate when the record shows no genuine dispute about a material fact and the moving party is entitled to judgment as a matter of law. The court viewed the evidence in the light most favorable to Campbell but did not weigh credibility disputes.

Campbell’s claim was based on alleged deliberate indifference to serious medical needs under the Eighth Amendment. To prove deliberate indifference, a prisoner must show a serious medical need and that an official actually knew of a substantial risk of serious harm and disregarded it by failing to take reasonable steps to address it. Negligence, even gross negligence, is not enough. A disagreement between a prisoner and medical professionals about treatment also does not establish deliberate indifference.

Court’s analysis

The court concluded that Campbell’s records and arguments did not create a triable issue about whether the defendants violated the Eighth Amendment by retaining him in administrative segregation or placing him in a double cell. The defendants relied on in-person evaluations, Campbell’s medical and disciplinary history, and assessments by multiple mental-health professionals. Those professionals concluded that Campbell was stable, had a chronic but not acute suicide risk, and could remain in administrative segregation with access to mental-health care.

As to double-cell housing, the court found that the defendants believed, although incorrectly in hindsight, that Campbell could safely have a cellmate. Their decision was based on mental-health assessments, Campbell’s lack of a significant history of predatory or in-cell violence, and Swearengin’s assessment that a cellmate could reduce Campbell’s opportunity to act on suicidal impulses. The court held that Campbell’s threats did not establish that the defendants actually drew the inference that he posed a substantial risk of serious harm to a cellmate or to himself. The court also found that Campbell did not link any defendant to the decision to place him in administrative segregation after the August 2 assault.

The court then ruled for each defendant. For Callis, it found no triable issue about whether he knew Campbell faced a substantial risk of serious harm or failed to take reasonable steps. For Swearengin, the court found that her incorrect assessment of the risk posed by double-cell housing amounted at most to negligence. For Hatton and Aguilera, the court found that the record did not show that they knew Campbell would carry out his threats or failed to take reasonable protective steps. For Gamboa, the court found that he did not present information to the committee, participate in its decision-making, or participate in the decision to establish double-cell housing. For Godinez and Thomas, the court found no evidence that they believed Campbell would carry out his threats or failed to address a known substantial risk.

Disposition

The court denied the defendants’ motion to strike and granted the defendants’ motion for summary judgment. It entered judgment in favor of the defendants and against Campbell, directed the Clerk to close the case, and stated that it did not need to conduct a further qualified-immunity analysis because it had found no constitutional violation.