HUCKABEE v. CSATF (2021)

United States Court of Appeals, Ninth Circuit.2021-04-28No. No. 20-15448

Summary · law.co

Holding. The district court's summary judgment in favor of the prison officials was affirmed because Huckabee failed to establish a genuine dispute of material fact showing deliberate indifference to serious medical needs, and the lower court did not abuse its discretion in denying leave to amend the complaint or in managing the motion practice.

Anthony Huckabee, a California state prisoner, sued under federal civil rights law claiming prison officials failed to provide adequate medical care by modifying and renewing his prescription for Timolol, a medication he was taking. The district court granted summary judgment against Huckabee on all claims, and he appealed. The appellate court reviewed the decision and found no errors.

The court determined that Huckabee failed to demonstrate genuine factual disputes regarding whether the officials acted with deliberate indifference to his serious medical needs. The court noted that deliberate indifference requires proof that an official knew of and ignored a substantial risk to the prisoner's health—mere medical mistakes or disagreements over treatment do not meet this standard. The court also upheld the trial judge's decisions to refuse Huckabee permission to file additional amended complaints and to allow one official to join another's motion for summary judgment.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether prison officials exhibited deliberate indifference to serious medical needs by modifying and renewing a prisoner's prescription
Whether the difference between medical malpractice and constitutional deliberate indifference
Whether leave to amend a complaint should be granted when further amendment would be futile

Procedural posture

Huckabee appealed pro se from a district court's grant of summary judgment in his Section 1983 civil rights action alleging deliberate indifference to medical needs.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

California state prisoner Anthony Huckabee appeals pro se from the district courts summary judgment in his 42 U.S.C. § 1983 action alleging deliberate indifference to his serious medical needs. We have jurisdiction under 28 U.S.C. § 1291. We review de novo. Toguchi v. Chung, 391 F.3d 1051, 1056 (9th Cir. 2004). We affirm.

The district court properly granted summary judgment for defendant Wu regarding the change in Huckabees Timolol prescription, and defendants Jimenez and McGuiness regarding the renewal of Huckabees Timolol prescription, because Huckabee failed to raise a genuine dispute of material fact as to whether defendants were deliberately indifferent to his serious medical needs. See id. at 1057-60 (deliberate indifference is a high legal standard, and a prison official is deliberately indifferent only if he or she knows of and disregards an excessive risk to the prisoners health; medical malpractice or negligence concerning the course of treatment does not amount to deliberate indifference).

The district court did not abuse its discretion by denying Huckabee leave to file a sixth amended complaint because amendment would have been futile. See Serra v. Lappin, 600 F.3d 1191, 1200 (9th Cir. 2010) (setting forth standard of review and factors for determining whether to grant leave to amend); Metzler Inv. GMBH v. Corinthian Colls., Inc., 540 F.3d 1049, 1072 (9th Cir. 2008) (“[T]he district courts discretion to deny leave to amend is particularly broad where plaintiff has previously amended the complaint.” (citation and internal quotation marks omitted)).

The district court did not abuse its discretion by permitting McGuiness to file a joinder in a motion for summary judgment filed by defendants Enenmoh, Jimenez, and Wu. See Christian v. Mattel, Inc., 286 F.3d 1118, 1129 (9th Cir. 2002) (setting forth standard of review and noting a district courts “considerable latitude in managing the parties’ motion practice”).

We do not consider matters not specifically and distinctly raised and argued in the opening brief. See Padgett v. Wright, 587 F.3d 983, 985 n.2 (9th Cir. 2009).

AFFIRMED.