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Prisoner Showed Good Cause for Extension of Time

The Tenth Circuit Court of Appeals held a district court erred in denying a prisoner’s motion for extension of time to respond to a dispositive motion.

Oklahoma state prisoner Archie Rachel, 71, filed suit in federal court regarding his medical treatment at the James Crabtree Correctional Center (JCCC). According to the district court, he alleged that “(1) he routinely had to wait outdoors in adverse conditions to receive his medications, (2) he received inadequate care from the prison’s medical staff, and (3) the prison’s grievance procedure was unfair.”

During the litigation, Rachel was given only “21 days to seek discovery, obtain and review responses that were not even due within the 21-day period, and respond to the defendants’ motion for dismissal or summary judgment.”

He moved for an extension of time, asserting that he only had a few hours in the law library each week. The district court did not rule on his motion so Rachel was forced to respond without the benefit of the requested discovery. The court dismissed his suit and he appealed.

The Tenth Circuit found the issue was whether Rachel showed good cause entitling him to the requested extension of time. It held good cause was shown pursuant to Fed.R.Civ.P. 6(b)(1), and concluded the extension of time should have been granted because the district court’s denial was an abuse of discretion. The Court of Appeals upheld the lower court’s orders denying appointment of counsel and a medical expert. Rachel litigated the appeal pro se. See: Rachel v. Troutt, 820 F.3d 390 (10th Cir. 2016).

Following remand, the district court denied Rachel’s motion for default judgment against one of the defendants. Then on April 21, 2017, the court adopted a magistrate judge’s report and recommendation related to motions to dismiss and for summary judgment, and entered judgment for the defendants.

“First,” the district court wrote, Rachel “failed to demonstrate that his delay in medical treatment led to any substantial harm. Second, the record shows that any complaints he had with his medical diagnosis and prescribed treatment and medications were merely disagreements and did not rise to the level of a constitutional violation. Third, he failed to demonstrate his having to wait outside in the JCCC’s ‘pill-line’ to receive his medication qualified as an easily recognizable risk that Defendants should have been aware. Fourth, because the record shows that Mr. Rachel suffered no deliberate indifference at the hands of Defendants, his claims for supervisory liability ... have no legs on which to stand.”

Rachel has again appealed the dismissal to the Tenth Circuit, and his appeal remains pending. See: Rachel v. Troutt, 2017 U.S. Dist. LEXIS 62662 (W.D. Okla. 2017). 

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Related legal case

Rachel v. Troutt