Anderson Purnell Thurston v. Babb, et al.

Summary

The United States District Court for the Eastern District of California screened a pro se former county inmate’s complaint against Yuba County Sheriff’s Deputies Babb and Dutt. The court found cognizable Fourteenth Amendment conditions-of-confinement claims based on alleged inadequate ventilation and delayed assistance during transport, but held that the equal protection claim was insufficiently articulated. The plaintiff was permitted to proceed on the cognizable claims or file an amended complaint, and the court corrected a defendant’s name on the docket.

Holdings

1. Because plaintiff appeared to have been a pretrial detainee, his allegations that defendants subjected him to inadequate conditions during transport and failed to respond adequately to his asthma attack were sufficient to proceed past screening as a Fourteenth Amendment claim.
2. The equal-protection claim could not proceed as currently articulated because plaintiff did not allege facts showing that defendants acted with an intent or purpose to discriminate against him based on membership in a protected class.

Questions Presented

1. Whether plaintiff's allegations that defendants exposed him to inadequate ventilation and delayed assistance during inmate transport stated a cognizable Fourteenth Amendment conditions-of-confinement claim.
2. Whether plaintiff's allegations of racially disrespectful remarks sufficiently stated an equal-protection claim under 42 U.S.C. § 1983.

Disposition

other