Guerrero v. Santa Rita Jail, et al.

Summary

The United States District Court for the Northern District of California orders service of Russell Guerrero’s second amended 42 U.S.C. § 1983 complaint on Doctors Magot and Cooper. The court finds that the complaint states a cognizable Fourteenth Amendment claim alleging objectively deliberate indifference to Guerrero’s worsening skin rash and sets deadlines for responsive pleadings and dispositive motions.

Holdings

1. A pretrial detainee states a cognizable Fourteenth Amendment medical-care claim against individual defendants by alleging that they intentionally made decisions concerning the detainee's confinement conditions, those conditions posed a substantial risk of serious harm, the defendants failed to take objectively reasonable available measures to abate the risk, and that failure caused injury. Guerrero's allegations that Dr. Magot and Dr. Cooper displayed reckless disregard for his worsening rash were sufficient at the screening stage.
2. The second amended complaint was not subject to dismissal under 28 U.S.C. § 1915A because it stated a cognizable Fourteenth Amendment claim against Dr. Magot and Dr. Cooper; the court therefore ordered service on those defendants.

Questions Presented

1. Whether Guerrero's second amended complaint stated a Fourteenth Amendment claim for inadequate medical care against Dr. Magot and Dr. Cooper.
2. Whether the complaint should be served on Dr. Magot and Dr. Cooper after screening under 28 U.S.C. § 1915A.

Disposition

other