Rafael Gonzalez v. Provider Ms. Hacker, et al.

Summary

The United States District Court for the Northern District of Ohio dismissed Rafael Gonzalez’s fee-paid prisoner civil-rights action under 28 U.S.C. § 1915A. The court held that the allegations did not state a Thirteenth Amendment claim and that the alleged inadequate medical care amounted, at most, to negligence, malpractice, or a disagreement over treatment rather than deliberate indifference under the Eighth Amendment. The court also certified that an appeal could not be taken in good faith.

Holdings

1. The complaint failed to state a plausible Thirteenth Amendment claim because it contained no allegation that Gonzalez was subjected to slavery or involuntary servitude.
2. The complaint failed to state a plausible Eighth Amendment deliberate-indifference claim because the alleged treatment, even if inadequate or negligent, did not amount to a complete denial of care or treatment so woefully inadequate as to constitute no treatment at all.
3. A fee-paid prisoner civil-rights complaint remains subject to mandatory screening and dismissal under 28 U.S.C. § 1915A when it is frivolous or fails to state a claim.

Questions Presented

1. Whether the complaint stated a plausible claim under the Thirteenth Amendment based on the alleged denial of medical care.
2. Whether the complaint stated a plausible Eighth Amendment deliberate-indifference claim based on the medical treatment provided by prison medical personnel.
3. Whether the action was subject to dismissal under 28 U.S.C. § 1915A despite payment of the filing fee.

Disposition

dismissed