GOODMAN v. Laurie Leclair; et al., Defendants. (2021)

United States Court of Appeals, Ninth Circuit.2021-08-23No. No. 20-15310

Summary · law.co

Holding. The court affirmed the district court's grant of summary judgment for the defendants because Goodman failed to create a triable factual dispute regarding whether the defendants knew of and disregarded an excessive risk to his health, as required for an Eighth Amendment claim of deliberate indifference.

Gregory Edward Goodman, a former Arizona Department of Corrections inmate, sued under federal civil rights law claiming that prison officials violated his Eighth Amendment rights by providing him with a nutritionally inadequate vegan diet. The district court granted summary judgment in favor of the defendants, and Goodman appealed on his own behalf.

The appellate court affirmed the lower court's decision. The court found that Goodman failed to establish a genuine dispute of material fact necessary for trial. Specifically, he did not present evidence that the dietician who created the vegan diet knew about health problems he experienced, nor did he demonstrate that the Facility Health Administrator either participated in or knew of violations and failed to stop them. Additionally, Goodman did not show that the administrator's inaction caused him harm. The court also declined to address Goodman's complaint about the denial of a document request because he did not adequately raise it in his appeal.

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

Key issues

Whether the dietician knew of health risks from the vegan diet
Whether the health administrator participated in or knew of violations and failed to prevent them
Whether the administrator's inaction caused harm to the inmate
Adequacy of factual disputes for Eighth Amendment deliberate indifference claims

Procedural posture

The appellate court reviewed de novo the district court's grant of summary judgment in this 42 U.S.C. § 1983 action alleging Eighth Amendment violations.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Gregory Edward Goodman, formerly an inmate in the custody of the Arizona Department of Corrections (“ADC”), appeals pro se the district courts summary judgment in his action under 42 U.S.C. § 1983 alleging that defendants violated his Eighth Amendment rights by providing a vegan diet that is nutritionally deficient. We have jurisdiction under 28 U.S.C. § 1291. We review de novo, Jett v. Penner, 439 F.3d 1091, 1096 (9th Cir. 2006), and we affirm.

The district court properly granted summary judgment for Donnelly, a registered dietician who developed the ADCs vegan diet, because Goodman did not raise a triable dispute as to whether she knew of the health issues that he allegedly suffered due to the vegan diet. See Farmer v. Brennan, 511 U.S. 825, 837, 114 S.Ct. 1970, 128 L.Ed.2d 811 (1994) (prison officials violate the Eighth Amendment only if they both know of and disregard an excessive risk to an inmates health or safety).

The district court properly granted summary judgment for Johnson, the ADCs Facility Health Administrator, because Goodman did not raise a triable dispute, first, as to whether she “participated in or directed [any] violations, or knew of the violations and failed to act to prevent them,” Taylor v. List, 880 F.2d 1040, 1045 (9th Cir. 1989), and second, as to whether Johnsons inaction caused him any harm, see Jett, 439 F.3d at 1096 (Eighth Amendment claim requires a showing of harm caused by defendants deliberate indifference).

We do not consider Goodmans contention that the district court erred in denying an unspecified request for documents. See Padgett v. Wright, 587 F.3d 983, 985 n.2 (9th Cir. 2009) (per curiam) (declining to consider matters not specifically raised and argued in the opening brief).

AFFIRMED.