Michael Alan Dean Hill v. County of El Dorado, et al.

Summary

The United States District Court for the Eastern District of California grants Michael Alan Dean Hill’s motion to proceed in forma pauperis. The court dismisses his 42 U.S.C. § 1983 complaint with leave to amend, finding that the allegations do not sufficiently establish objective deliberate indifference, municipal liability, or personal participation by the named defendants.

Holdings

1. The complaint failed to state a Fourteenth Amendment claim because the allegations against Dr. Chapman and Nurse Jennifer showed, at most, negligence, lack of due care, or medical malpractice, and did not plausibly allege objectively unreasonable conduct creating or disregarding an obvious substantial risk of serious harm.
2. The complaint failed to state a municipal-liability claim because bare allegations of failure to train and supervise, together with conclusory assertions that defendants knew or should have known about substandard care, did not show deliberate indifference by municipal policymakers.
3. The complaint failed to state claims against the named correctional officers and sergeants because it did not allege how each individual personally participated in the alleged constitutional deprivation.
4. The complaint was dismissed with leave to amend because it was possible that plaintiff could allege additional facts sufficient to state a claim.

Questions Presented

1. Whether the complaint stated a Fourteenth Amendment medical-care claim by a pretrial detainee under 42 U.S.C. § 1983.
2. Whether the complaint stated a municipal-liability claim against El Dorado County or the El Dorado County Sheriff’s Department based on alleged failure to train and supervise medical personnel.
3. Whether the allegations adequately established personal participation by the individually named correctional officers and sergeants.
4. Whether the complaint should be dismissed under 28 U.S.C. § 1915A or whether plaintiff should receive leave to amend.

Disposition

dismissed