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Federal Suit Targets Dangerous, Unconstitutional Conditions in Fresno County, California Jail System

Fresh off their recent victory in Plata v. Brown, where the U.S. Supreme Court held that overcrowding is the primary cause of constitutionally inadequate medical and mental health care in California’s prison system [See: PLN, July 2011, p.1], attorneys at the Prison Law Office, joined by Disability Rights California and attorneys with the law firm of Cooley LLP, filed a class-action lawsuit in December 2011 against Fresno County officials.

The suit alleges systemic failures to 1) provide minimally adequate health care to Fresno County jail prisoners and 2) protect those prisoners from injury and violence from other prisoners, in violation of the Eighth and Fourteenth Amendments to the U.S. Constitution. The suit, filed in federal court, seeks declaratory and injunctive relief. It is related to the Plata case in that state officials have responded to the Plata court’s order to reduce prison overcrowding by implementing a massive “realignment” plan, whereby tens of thousands of prisoners formerly sent to state prison to serve time for parole violations and/or low-level offenses are now being housed in county jails instead.

The realignment plan, it is anticipated, will effectively shift much of the overcrowding problem from California’s prison system to its county jails, and the Fresno County suit seeks to minimize the resulting harm to prisoners, at least in one major county jail system. Fresno County houses 2,300 prisoners in three facilities – a number that is expected to rise due to realignment – and the class-action suit addresses conditions at the jails, which are already dangerous and substandard, before they become even worse due to overcrowding.

The named plaintiffs in the suit include prisoner Quentin Hall, who has serious mental health issues (recurring psychosis, depression, anxiety and insomnia); another male prisoner, Robert Merryman, who suffers from serious and chronic diseases (COPD and hypertension) and was the victim of an attack by another prisoner; female prisoner Dawn Singh, diagnosed with Crohn’s disease, who has suffered serious medical symptoms (hemorrhaging, abdominal pain and cramping, diarrhea, fevers, dehydration and fatigue) for two years as a result of the defendants’ failure to adequately treat her; and a male prisoner who suffers from painful and bleeding gums and is at risk of irreversible tooth decay as a result of the defendants’ failure to provide him with timely, adequate dental care.

“Most detainees in the jail are awaiting trial and have not been convicted of any crimes. They are dependent on the jail for all their medical needs,” stated Kelly Knapp, an attorney with the Prison Law Office. “To leave them in pain, at risk of life-threatening injury and permanent disability is simply inhumane.”

With respect to the failure-to-protect claim, the lawsuit alleges that as a result of understaffing and failure to adequately classify prisoners, as well as structural deficiencies (blind spots) in the jail system, fights between prisoners regularly occur and vulnerable prisoners are routinely victimized.

In regard to health care, the suit alleges that there is an insufficient number of medical, dental and mental health clinicians, particularly overnight; that the screening and intake process for serious illnesses, mental health conditions and communicable diseases is inadequate; that the process for requesting health care is inadequate and results in unreasonable delays; that the care ultimately received is insufficient (with prisoners often being labeled as “drug-seeking” or “malingering” when they make legitimate requests for medication, and with dental care limited to tooth extraction); that defendants fail to keep complete and adequate health care records; that force and/or solitary confinement are often inappropriately used to control prisoners suffering from serious mental health conditions; that suicide precautions are inadequate; that housing conditions are substandard; and that prisoners with serious medical conditions are released without measures to ensure that their health care is not disrupted.

On May 16, 2012 the district court denied a motion to dismiss the case, noting that the defendants “ignore well-settled standards” regarding motions under Fed.R.Civ.P. 12(b)(6). The court found that the plaintiffs had presented “specific allegations to support each of the areas that [they] claim are deficient in the Fresno County jail system.” As the court may draw inferences in favor of the plaintiffs from the allegations in the complaint at the pleading stage, the defendants’ motion to dismiss was accordingly denied. This case remains pending. See: Hall v. Mims, U.S.D.C. (E.D. Cal.), Case No. 1:11-cv-02047-LJO-BAM.

Additional source: PLO/DRC press release

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Related legal case

Hall v. Mims