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Ninth Circuit: Plata Doesn’t Bar Individual Injunctive Relief Claims; $26,000 Settlement

Ninth Circuit: Plata Doesn’t Bar Individual Injunctive Relief Claims; $26,000 Settlement

by Mark Wilson

The Ninth Circuit Court of Ap­peals has held that an individual California prisoner’s medical care injunctive relief claims are not barred by Plata v. Brown, the class-action suit that seeks systemic reform of California’s prison healthcare system.

A three-judge federal court ordered the Plata defendants to reduce the population of the state’s prison system to 137.5% of design capacity within two years, a ruling that was affirmed by the U.S. Supreme Court. [See: PLN, July 2011, p.1].

On April 11, 2013, the three-judge court denied the defendants’ motion to vacate or modify the release order, reasserting that they “must reduce the California prison population to 137.5% of design capacity.”

The Plata defendants sought a stay of the prison population reduction order, which was denied by the Supreme Court in August 2013. [See: PLN, Sept. 2013, p.21].

Meanwhile, California state prisoner David Codell Pride, Jr., who suffers from shoulder and knee injuries, was confined at the Pelican Bay State Prison. His medical conditions were treated with a double mattress and a knee brace.

When Pride was transferred to Calipatria State Prison, he again sought treatment for his shoulder and knee injuries. Dr. Santiago prescribed a knee brace and an egg crate mattress; however, a “Chrono Committee” reviewed the doctor’s order and denied the prescribed items.

After exhausting his administrative remedies, Pride filed a pro se federal civil rights complaint alleging that prison officials acted with deliberate indifference to his serious medical needs. He sought damages and injunctive relief.

The defendants moved to dismiss pursuant to F.R.C.P. 12(b)(6), “solely on the ground that Pride’s claim for injunctive relief ‘cannot be’ brought independently of the Plata class-action.” The district court construed the motion as an F.R.C.P. 12(b)(1) motion to dismiss “‘for lack of jurisdiction over the subject matter because the claim is currently pending as a class action.’” The court granted the defendants’ motion and dismissed Pride’s claim for injunctive relief.

Pride appealed and the Ninth Circuit reversed. Noting “that the Plata class seeks systemic reform of medical care in the California prisons,” the appellate court explained that “individual claims for injunctive relief related to medical treatment are discrete from the claims for systemic reform addressed in Plata.” Consequently, “where a California prisoner brings an independent claim for injunctive relief solely on his own behalf for specific medical treatment denied to him, Plata does not bar the prisoner’s claim for injunctive relief.” Individual claims seeking systemic injunctive relief related to prison medical care would be barred, however, if Plata addressed the same issues.

Finding “there are no references in Pride’s complaint to systemic relief for inmates generally,” the Court of Appeals held that his individual claim for injunctive relief was not duplicative of those in the Plata litigation and the district court had improperly dismissed his complaint. See: Pride v. Correa, 719 F.3d 1130 (9th Cir. 2013).

Following remand and a mandatory settlement conference, the case settled in June 2014 for $26,000. As part of the settlement, Pride agreed to dismiss another lawsuit he had pending against state prison officials.

As of May 2015, California’s prison population had been reduced to under 111,400 prisoners in the 34 state facilities governed by the Plata order – below the court-imposed 137.5% population cap. The total prison population, including in-state contract beds and prisoners housed at out-of-state facilities, was around 129,500.


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Related legal case

Pride v. Correa