ALLRED v. Duroy; et al., Defendants-Appellees. (2021)

United States Court of Appeals, Ninth Circuit.2021-01-26No. No. 19-16770

Summary · law.co

Holding. The district court's summary judgment in favor of the defendants was affirmed because the prisoner failed to establish a genuine dispute of material fact regarding deliberate indifference to his medical needs or significant harm resulting from any treatment delay.

Jesse Allred, a state prisoner, appealed a district court's decision granting summary judgment to defendants in a civil rights lawsuit alleging that prison officials were deliberately indifferent to his serious medical needs, specifically regarding treatment of a wrist fracture. The appellate court reviewed the case and found that Allred had not presented sufficient evidence to create a genuine factual dispute on the key questions: whether the defendants acted with deliberate indifference and whether any delay in treatment caused him significant harm. The court emphasized that mere negligence or disagreement about treatment methods does not satisfy the legal standard for deliberate indifference in prison medical cases.

Allred also challenged the district court's denial of his discovery motion, but the appellate court found no abuse of discretion because he failed to show that the denied discovery caused him actual and substantial prejudice. The court rejected all of Allred's arguments and upheld the lower court's decision.

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Key issues

Whether prison officials were deliberately indifferent to inmate's serious medical needs
Whether a delay in treatment of a wrist fracture caused significant harm
Whether denial of discovery resulted in actual and substantial prejudice to the prisoner

Procedural posture

A pro se state prisoner appealed the district court's grant of summary judgment in a § 1983 civil rights action to the appellate court for de novo review.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

California state prisoner Jesse Allred 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 because Allred failed to raise a genuine dispute of material fact as to whether defendants were deliberately indifferent to his wrist fracture and whether he experienced significant harm as a result of any delay in treatment. See id. at 1060-61 (a prison official is deliberately indifferent only if he or she knows of and disregards an excessive risk to inmate health; medical malpractice, negligence or difference of opinion concerning the course of treatment does not amount to deliberate indifference); Hallett v. Morgan, 296 F.3d 732, 745 (9th Cir. 2002) (prisoner must show delay led to significant harm).

The district court did not abuse its discretion by denying Allreds discovery motion because Allred failed to demonstrate that the denial of discovery resulted in actual and substantial prejudice to him. See Laub v. U.S. Dept of Interior, 342 F.3d 1080, 1084, 1093 (9th Cir. 2003) (setting forth standard of review and explaining that a district courts “decision to deny discovery will not be disturbed except upon the clearest showing that the denial of discovery result[ed] in actual and substantial prejudice to the complaining litigant” (citation and internal quotation marks omitted)).

We reject as without merit Allreds contention that the district court applied an incorrect legal standard in granting summary judgment for the defendants.

Allreds motion to file an oversized brief (Docket Entry No. 21) is granted. The Clerk is instructed to file the reply brief submitted at Docket Entry No. 22.

AFFIRMED.