Morris v. Aranas

1 |} AARON D. FORD Attorney General || DOUGLAS R. RANDS, Bar No. 3572 Senior Deputy Attorney General || State of Nevada N. Carson Street || Carson City, NV 89701-4717 Tel: (775) 684-1150 || E-mail: [email protected] || Attorneys for Defendants Romeo Aranas, Isidro Baca, Shelly Conlin, || Richard Long, David Mar, Melissa Mitchell and William Miller 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA |} CHARLES MORRIS, Case No. 3:18-cv-00310-RCJ-CLB 12 Plaintiff, || vs. JOINT PRE-TRIAL ORDER || ROMEO ARANAS, et al.

15 Defendants.

1? Following pretrial proceedings in this case, 18 IT IS ORDERED: 19 NATURE OF ACTION AND CONTENTIONS OF THE PARTIES 20 A. NATURE OF ACTION 21 Plaintiff Charles Morris (Morris) is an inmate in the custody of the Nevada Department of |} Corrections (NDOC) and currently incarcerated at Northern Nevada Correctional Center (NNCC).

23 || Morris is proceeding on two claims: an Eighth Amendment deliberate indifference to serious medical |)needs claim against Defendants Aranas, Long, Mitchell, and Mar, and an Eighth Amendment || deliberate indifference to serious threats to inmate’s safety claim against Defendants Baca, Miller, and || Conlin. ECF No. 43.

2; On June 21, 2021, Defendants filed a Motion for Summary Judgment. (ECF No. 65). Plaintiff || opposed (ECF No. 82) and filed a cross motion for summary judgment (ECF No. 83). Defendants ] || opposed Plaintiff's Motion for Summary Judgment. ECF No. 84. In an Order adopting and accepting || the Report and Recommendation of the U.S. Magistrate Judge, this Court denied Defendants’ Motion || for Summary Judgment (ECF No. 65) and denied Plaintiff's Cross-Motion for Summary Judgment || (ECF No. 83).

5 Therefore, this matter is proceeding to trial 6 B. CONTENTIONS OF THE PARTIES 7 ds Plaintiff's Contentions ac Should have, 8 Morris alleges prison officials knewlhe had serious back problems and, repeatedly transferred || him to prisons with flat yards and delayed medical treatment by refusing to provide MRIs, then || delayed/denied surgery once an MRI confirmed the need for surgery. Instead of surgery, prison || officials issued Morris a walker and cane. Morris’s delay in treatment led ee himself on the |} stairs, which led to the need for emergency surgery.

13 Morris alleges prison officials knew fortis years that he was classified to a lower tier, lower |} bunk restriction, but in 20)8, prison officials ordered Morris to a top tier and refused to move him to a || lower tier until he fell down the stairs and partially paralyzed himself.

16 2. Defendants’ Contentions 17 Defendants contend that the evidence does not support Plaintiff's allegations. Defendants || incorporate any Affirmative Defenses from the Answer as it pertains to the Defendants. Defendants || deny that Plaintiffs constitutional rights have been violated.

20 c. RELIEF SOUGHT Plaintiff seeks declaratory, compensatory, and punitive damages. injunclive cell of, Cour Cosi, Out of preket expense, kocney ees, Menkal ane emohianal cayiages || I. STATEMENT OF TURISDICTION 23 This is a civil action commenced under 42 U.S.C. § 1983. This Court has jurisdiction pursuant || to 28 U.S.C. § 1331.

25 || I. UNCONTESTED FACTS ADMITTED BY THE PARTIES WHICH REQUIRE NO PROOF 27 L. Mr. Morris, in this matter has filed a Complaint alleging violations of his constitutional || rights under the Eighth Amendment. (ECF No.6).

1 Zz. At all times relevant in the Complaint, Plaintiff was in the lawful custody of the || Nevada Department of Corrections (“NDOC”) housed at Northern Nevada Correctional Center 3. || (NNCC) (ECF No. 6 at 1).

4 3. Defendant Romeo Aranas was previously employed by the NDOC as a Medical || Director.

6 4. Defendant David Mar was previously employed by the NDOC as a Senior Physician. a Defendant Melissa Mitchell is ssnleife employed by the NDOC as a Correctional || Nurse, III.

9 6. Defendant Richard Long is currently a contract Physician with the NDOC.

10 Te Defendant Isidro Baca was previously employed by the NDOC as a Warden.

11 8. Defendant Shelly Conlin is currently employed by the NDOC as a Correctional |] Caseworker, III.

13 9. Defendant William Miller is currently employed by the NDOC as a Correctional || Lieutenant.

15 10. Plaintiff suffered from back pain. | 16 11. Plaintiff was given a lower bunk, lower level designation.

17 Te. Plaintiff received medical consultations and evaluations.

18 13. Plaintiff received MRI and other evaluations.

19 14. Plaintiff was moved to a different cell due to contraband being found in his cell.

20 15. Plaintiff fell down the stairs.

16. — Plaintiff had surgery, on an same basis after the fall.

22 ly. Plaintiff kited for medical attention phroughout the time frame of this matter.

23 18. Plaintiff filed grievances relating to his treatment.

24 IV. FACTS UNADMITTED THAT WILL NOT BE CONTESTED 25 The following facts, though not admitted, will not be contested at trial by evidence to the || contrary: NONE | /// 28 /// || V. CONTESTED ISSUES OF FACT TO BE TRIED AND DETERMINED UPON TRIAL 2 A. PLAINTIFF’S CONTESTED FACTS 3 See Complaint.

4 B. DEFENDANTS’ CONTESTED FACTS 5 l. Whether Plaintiff has met his burden of producing evidence supporting the facts set || forth above, i.e., whether he can prove that the individual defendants violated his Eighth Amendment || rights?

8 2. Whether any form of damages are available to Plaintiff for any alleged failures?

9 || VI. CONTESTED ISSUES OF LAW TO BE TRIED AND DETERMINED UPON TRIAL 10 A. PLAINTIFF be Whether or not the claims against Defendants, violated Plaintiff's Constitutional rights, || and do the facts warrant a damage award?

13 B. DEFENDANTS 14 bs Did Defendants individually violate Plaintiff's constitutional rights?

15 a Did Mr. Morris prove the elements of a violation of his Eighth Amendment rights?

16 || Prison officials have a duty to provide medical care for inmates, and the denial of medical care may || result in pain and suffering constituting cruel and unusual punishment in violation of the Eight || Amendment of the Constitution. Estelle v. Gamble, 429 U.S. 97, 103 (1976). Prison officials can be || deliberately indifferent to serious medical needs by “intentionally denying or delaying access to || medical care or intentionally interfering with the treatment once prescribed.” Id. at 104-05. To || establish a constitutional violation, an inmate must satisfy a two-part test: (1) that he has a “serious || medical need,” the “failure of which to treat “could result in further significant injury or the || unnecessary and wanton infliction of pain”; and (2) that the “defendant’s response to the need was || deliberately indifferent.” Jett v. Penner, 439 F.3d 1091, 1096 (9th Cir. 2006) (internal quotation || omitted). To determine whether the defendants’ response was deliberately indifferent, an inmate must || show the following: (1) the defendants purposefully acted or failed to respond to the inmate’s possible || medical need; and (2) the indifference caused harm.” Id. Notably, defendants’ conduct must || demonstrate “unnecessary and wanton infliction of pain” before it violates the Eighth Amendment.

2 || Estelle, 429 U.S. at 104-05.

3 “Deliberate indifference is a high legal standard.” Toguchi v. Chung, 391 F.3d 1051, 1060 (9th || Cir. 2004). Every claim by an inmate that he has not received adequate medical treatment does not || constitute an Eighth Amendment violation. Estelle, 429 U.S. at 105. An inmate alleging deliberate || indifference to serious medical need “must allege acts or omissions sufficiently harmful” to the || inmate. /d. at 106. For example, a medical professional’s mistake, negligence, or malpractice is not || sufficient to constitute deliberate indifference. Toguchi, 391 F.3d at 1060. A medical decision not to || order certain testing may qualify as medical malpractice, but it does not rise to the level of deliberate 10 indifference to a serious medical need. Estelle, 429 U.S. at 107-108. A difference of medical opinion || regarding course of treatment is insufficient to establish a claim of deliberate indifference to a serious || medical condition. Toguchi, 391 F.3d at 1058.

13 The “treatment a prisoner receives in prison and the conditions under which he is confined are || subject to scrutiny under the Eighth Amendment.” Helling v. McKinney, 509 U.S. 25, 31 (1993).

15 |} Conditions of confinement may, consistent with the Constitution, be restrictive and harsh. Rhodes v. || Chapman, 452 U.S. 337, 347 (1981). However, “[p]rison officials have a duty to ensure that prisoners || are provided adequate shelter, food, clothing, sanitation, medical care, and personal safety.” Johnson || v. Lewis, 217 F.3d 726, 731 (9" Cir. 2000).

19 To challenge the conditions of confinement under the Eighth Amendment, a plaintiff must || meet both an objective test and subjective test. Jd. The objective prong requires a showing that the || deprivation was sufficiently serious to form the basis for an Eighth Amendment violation. Johnson at || 731. When determining whether the conditions of confinement meet the objective prong, the court |}must analyze each condition to determine whether that specific condition violates the Eighth || Amendment. Toussaint v. McCarthy, 801 F.2d 1080, 1107 (9" Cir. 1986). When considering the || conditions of confinement, a court also should consider the amount of time to which the prisoner was || subjected to the condition. Hearns v. Terhune, 413 F.3d 1036, 1042 (9" Cir. 2005). Speculative and || generalized fears of harm do not rise to a sufficiently substantial risk of serious harm. Williams v. || Wood, 223 Fed. Appx. 670, 671, 2007 WL 654223, at 1 (9 Cir. 2007).

1 As to the second prong of the Eighth Amendment analysis, prisoners must establish prison || officials “deliberate indifference” to the unconstitutional conditions of confinement to establish an || Eighth Amendment violation. Farmer v. Brennan, 511 U.S. 825, 834 (1994). To demonstrate that a || prison official was deliberately indifferent to a serious threat to the inmate’s safety, the prisoner must Shanrlel have. Knew?

5 || show that “the official [knew] or and disregard]ed] an excessive risk to inmate . . . safety; the official || must both be aware of facts Son which the inference could be drawn that a substantial risk of serious || harm exists, and [the official] must also draw the inference,” (/d. at 837). Mere negligence is || insufficient to show a violation of the Eighth Amendment. (/d. at 835-36).

9 VU. EXHIBITS 10 A. STIPULATED EXHIBITS AS TO AUTHENTICITY AND ADMISSIBILITY Le Administrative Regulation 740.

12 B. STIPULATED EXHIBITS AS TO AUTHENTICITY BUT NOT 13 ADMISSIBILITY 14 None.

15 C. PLAINTIFF’S EXHIBITS SUBJECT TO OBJECTIONS 16 See adhoch ments:

25 D. DEFENDANT’S EXHIBITS SUBJECT TO OBJECTIONS 26 Ls Plaintiff's Movement History Report; at Z. Plaintiff's Housing History Report; 28 3. Plaintiff's Grievance file, including all relevant grievances; Oo, fy VoAae 1 4, Certified Judgment(s) of Conviction of Plaintiff for underlying offense (only if needed || for impeachment); ab, not relevent 3 5. Plaintiff's Institutional File (“I-File”); Glo, NOt relevent f 4 6. Grievance 2006-30-26975.

5 + Grievance 2006-30-63488 6 8. Plaintiff's Medical Records and Consultation Reports.

7 9. NOTIS Disciplinary History Report. 04, NOE reavent 8 10, IR-2018-NNCC-000300, 9 11. IR-2018-NNCC-002639, 10 12. OIC 433158 reports, Lt 13: AR 707, “Inmate Disciplinary Process,” effective May 16, 2017.

12 14. AR 707.1, “Inmate Disciplinary Manual,” effective February 22, 2017.

13 i. AR 707.2, “Chart of Disciplinary Sanctions,” effective February 13, 2017.

14 16. Plaintiff's Case Notes as maintained on the NDOC NOTIS system from 2014 to || Present.

16 1 All prison logs, registers, documents, or other form of data pertaining to any and all of || Plaintiff's claims. ab @e cele aterk 18 18. Any and all other exhibits that may support the statements of fact and law cited herein || and to rebut Plaintiff's statements, claims, and testimony. ab ue ve 20 19. Any and all other exhibits that rebut witnesses that might be called to respond to claims || made by either Plaintiff or any of his proposed witnesses; lo 22 E. DEPOSITIONS 23 I. None.

24 || VOI. WITNESSES 25 A. PLAINTIFEF’S WITNESSES: 26 Plaintiff wishes to reserve the right to call the following persons: 6 B. DEFENDANT’S WITNESSES: T Defendant wishes to reserve the right to call the following persons: 8 l. Plaintiff Charles Morris, Inmate, NNCC; 9 2. Isidro Baca, Defendant, c/o Douglas R. Rands, Office of Attorney General, 100 N.

10 || Carson St. Carson City, Nevada 89701-4717.

1! 3. Romeo Aranas, Defendant, c/o Douglas R. Rands, Office of Attorney General, 100 N.

12 || Carson St. Carson City, Nevada 89701-4717.

13 4, David Mar, Defendant, c/o Douglas R. Rands, Office of Attorney General, 100 N.

14 || Carson St. Carson City, Nevada 89701-4717.

15 2. Warden Nethanjah Brietenbach, c/o Douglas R. Rands, Office of Attorney General, 100 || N. Carson St. Carson City, Nevada 89701-4717.

17 6. Harold Wickham, Former Deputy Director, c/o Douglas R. Rands, Office of the || Attorney General, 100 N. Carson Street, Carson City, NV 89701-4717, (775) 684-1100.

19 □□ Melissa Mitchell, Defendant, c/o Douglas R. Rands, Office of Attorney General, 100 N.

20 |} Carson St. Carson City, Nevada 89701-4717.

8. Richard Long, Defendant, c/o Douglas R. Rands, Office of Attorney General, 100 N.

22 || Carson St. Carson City, Nevada 89701-4717.

23 9, Shelly Conlin, Defendant, c/o Douglas R. Rands, Office of Attorney General, 100 N.

24 |! Carson St. Carson City, Nevada 89701-4717.

25 10. William Miller, Defendant, c/o Douglas R. Rands, Office of Attorney General, 100 N.

26 || Carson St. Carson City, Nevada 89701-4717.

Il. © NDOC Medical Director, c/o Douglas R. Rands, Office of Attorney General, 100 N.

28 || Carson St. Carson City, Nevada 89701-4717.

1 12. Custodian(s) of Record for any exhibits identified above, c/o Douglas R. Rands, Office || of the Attorney General, 100 N. Carson Street, Carson City, NV 89701-4717, and (775) 684-1100.

3 13 Any and all rebuttal witnesses that might be called to respond to claims made by either || Plaintiff or any of his witnesses.

5 14. Any and all other witnesses that have personal knowledge supporting Defendant’s \ 2 || statements of fact or law cited herein. él, ushe ¢ 15. witnesses identified by Plaintiff, whether or not called to testify at trial.

8 Plaintiff and Defendant reserve the right to interpose objections to the calling of any named || witness listed above prior to or at trial.

10 || 1X. AVAILABLE TRIAL DATES 11 Plaintiff and Defendant’s Counsel expressly understand that the Clerk shall set the trial of this || matter at the convenience of the Court's calendar. A jury has been requested.

13 The following are three weeks in which both parties are available: 14 3 September 11, 2023 Lal shouldbe 3-1 days 15 September 18, 2023 16 September 25, 2023 Ly DATED this day of January, 2023.

19 eer AARON D. FORD Attorney General 21 L □□□ tS By: /s/ Douglas R. Rands CHARLES MORRIS DOUGLAS R. RANDS, Bar No. 3572 22 Plaintiff Senior Deputy Attorney General || IT IS ORDERED that Jury Trial is Attorneys for Defendants scheduled for Monday, September 11, 2023, at 8:30 a.m. in Reno Courtroom 3 before || Judge Robert C. Jones. Calendar Call is _ || scheduled for Monday, August 14, 2023, at |! 10:00 a.m. in Reno Courtroom 3 before || Judge Robert C. Jones. .

28 || DATED: 2/1/2023 ROBERT C. JONES, U.S. DISTRICT JUDGE 1 CERTIFICATE OF SERVICE 2 I certify that | am an employee of the State of Nevada, Office of the Attorney General, and that 3 January 30, 2023, I electronically filed the foregoing, [PROPOSED] JOINT PRE-TRIAL || ORDER, via this Court’s electronic filing system. Parties that are registered with this Court’s ||} electronic filing system will be served electronically. For those parties not registered, service was || made by depositing a copy for mailing in the United States Mail, first-class postage prepaid, at Carson || City, Nevada, addressed to the following: 8 Charles Morris, #62773 Northern Nevada Correctional Center 9 P.O. Box 7000 Carson City, Nevada 89702 12 oe □□□ a ec An employee of the 13 Office of the Nevada Attorney General zi

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