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California: Prison Appeals Coordinator Who Rejected Dental Complaints Held Liable for $1,500 in Damages

Proceeding pro se, California prisoner Earnest C. Woods II survived a summary judgment motion and was awarded $500 in compensatory damages and $1,000 in punitive damages after a jury found that CSP-Solano Appeals Coordinator Santos Cervantes had maliciously violated his Eighth Amendment rights by repeatedly rejecting, on procedural grounds, Woods’ legitimate complaints regarding inadequate dental care.

Woods filed an amended § 1983 complaint in October 2004 alleging that for two years, beginning with his arrival at CSP-Solano in August 2002, he was denied adequate dental care with respect to his broken tooth and a broken partial. He advanced two legal claims: that the insufficient dental care violated his Eighth Amendment rights and that the inade-quate administrative appeals process violated his due process rights.

Woods sued Warden Tom L. Carey and CSP-Solano’s two administrative appeals coordinators, T. Dickenson and Cervantes. Ruling on the defendants’ motion for summary judgment, the district court, relying on Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) [PLN, Jan. 2005, p.36], held that Woods’ due process claim failed because prisoners have no constitutional right to any specific grievance procedure. The court also dismissed Dickinson as a defendant because there was no evidence linking anyone other than Cervantes to the denial of Woods’ administrative appeals. The district court held, on the other hand, that Cervantes could be found liable for his role in adjudicating Woods’ administrative grievances because the record showed that Cervantes’ rejections of the grievances could reasonably be interpreted as a ratification of a policy at the prison to provide inadequate dental care.

Significant to the court’s conclusion in this regard was the fact that the record did not unequivocally support the pro-cedural grounds that Cervantes had cited when rejecting Woods’ appeals. Cervantes first asserted that Woods had failed to attempt to resolve his problem at the informal level. A second appeal, he argued, was untimely filed. The court relied on statements and dates in the rejected appeals themselves to find that the asserted procedural grounds could be a pretext to cover for Cervantes’ unwillingness to respond to Woods’ legitimate complaints regarding inadequate dental care. Ulti-mately the jury agreed, awarding $1,500 in total damages. The parties have both filed appeals. See: Woods v. Carey, U.S.D.C. (E.D. Cal.), Case No. 2:04-cv-01225-LKK-GGH.

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Related legal case

Woods v. Carey