Lacen v. Aygemong

Background

Jose R. Lacen, proceeding without a lawyer, sued EMTC Captain Aygemong, Janet Runcie, Achim Huggins, David Onuora, and Sai Kolla under 42 U.S.C. § 1983. The court construed his complaint as asserting claims for unconstitutional conditions of confinement and inadequate medical care. Lacen alleged that, while serving a sentence at the Eric M. Taylor Center, he experienced worsening back pain after being denied an extra or thicker mattress. He alleged that he had previously undergone spinal surgery and continued to experience extreme pain, numbness, and discomfort.

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim. In considering that motion, the court treated the complaint’s factual allegations as true and considered medical records attached to the complaint.

Conditions-of-Confinement Claim

For an inadequate-mattress claim under the Eighth Amendment, the court explained that a prisoner must allege a medical condition requiring a nonstandard bed, that officials knew about the condition, that the prisoner requested such a bed, and that an official knowingly disregarded an excessive health or safety risk.

The court found that Lacen plausibly linked the worsening of his back problems to the mattress. But it concluded that he did not adequately allege deliberate indifference—the knowing disregard of a serious health risk. The records showed that medical staff saw Lacen regularly, prescribed medication, referred him to neurology and physical therapy, provided an extra blanket, and took steps to explore whether he could receive another mattress. The court also noted that Dr. Huggins did not find that Lacen’s condition required a nonstandard bed. The court therefore dismissed the conditions-of-confinement claim.

Inadequate-Medical-Care Claim

The court likewise dismissed Lacen’s inadequate-medical-care claim. It found that he was regularly treated by physicians and physician assistants, received medication, and was offered physical therapy. Captain Aygemong also contacted a housing officer about providing a thicker mattress when one became available. The court held that Lacen’s disagreement with the treatment he received did not establish deliberate indifference or a constitutional claim.

Official-Capacity Claims

The court dismissed the claims against the defendants in their official capacities because Lacen did not allege that a municipal policy or custom caused a violation of his constitutional rights, as required for municipal liability under Monell v. Department of Social Services.

Disposition

The court granted the defendants’ motion to dismiss. Because Lacen’s first amended complaint had been filed without the benefit of the court’s analysis, the court permitted him to file another amended complaint by August 31, 2020. The order did not state that the dismissal was with or without prejudice.