A federal magistrate judge in San Francisco refused last week to dismiss inmate claims that medical care at Santa Rita Jail in Dublin is so inadequate that it violates the U.S. Constitution.
The ruling came in a civil rights lawsuit originally filed in 2019 after a hunger strike and work stoppage by several hundred inmates protested unsanitary conditions and inadequate medical care at the jail.
The suit was styled as a class action of current and former inmates at Santa Rita and challenged 20 conditions of confinement as violations of the inmates' civil rights under a number of constitutional provisions, including the 8th Amendment (cruel and unusual punishment) and the 14th Amendment (denial of due process).
The defendants included Alameda County, the Alameda County Sheriff's Office, and a number of jail officers.
In addition, plaintiffs sued Aramark Correctional Services LLC, a private company that provides food services at the prison, and Wellpath Management Inc., a for-profit health care company that provides medical care to the inmates.
Santa Rita Jail in Dublin is a medium-security facility serving greater Alameda County. According to the complaint, Santa Rita is the largest county jail in the Bay Area.
As of March 27, the jail population was 2,583, of which 2,324 were male and 224 female, according to Inmate 101, an informational website operated by a consulting group for inmates and families.
As a county jail, a major function of Santa Rita is to detain individuals who have been refused pre-trial release or have been unable to make bail. Some 85% of the jail population are pre-trial detainees.
Through a series of motions to dismiss the lawsuit, the defendants have been successful in whittling down the claims in the case, as the court struck allegations and theories that did not meet federal standards.
In March of this year, the plaintiffs filed their fourth amended complaint. That complaint -- now down to seven claims -- portrayed the jail's operation as driven by financial policies designed to denigrate inmates and deprive them of adequate food, sanitation and medical care.
The complaint describes the jail as being run in accordance with a policy of "fiscal tightfisted, penny pinching control of prisoner services, resulting in limited and reduced prisoner services."
The plaintiffs contended that the jail is run by guards and officers being paid excessive compensation, even as funds spent on services and care at the jail have decreased.
The complaint states that "being a jail guard at SRJ is one of -- if not the most -- remunerative jobs in the entire county that a high school graduate with no college education can get. Starting jail guards make approximately $100,000 per year in salary and benefits."
The complaint's focus on financial policy is consistent with the plaintiffs' challenge to their conditions of confinement under the federal civil rights laws.
In order to obtain relief against local governmental entities like Alameda County, plaintiffs must show more than one-time incidents. They must establish that there is a specific policy or practice put in place by the government -- or allowed by the government to continue after learning about it -- that results in depriving a person of their constitutional rights.
Central to the policy argument are the complaint's allegations concerning Wellpath, a Delaware corporation formerly known as California Forensic Medical Corporation.
The complaint says that Wellpath is the nation's largest for-profit provider of health care services to correctional facilities, and it has "a pattern and practice of providing inadequate medical care by denying or unreasonably delaying medical care, reducing or denying medication and refusing to provide medical devices."
The plaintiffs allege that Wellpath has a contract with the sheriff to provide "all healthcare services of any type needed by any prisoner at the jail," including "medical, dental, prenatal and opioid treatment services."
The contract allegedly gives Wellpath sole authority to determine "the necessity and appropriateness of inpatient hospital care and other outside medical services."
The contract makes Wellpath "solely responsible for all costs incurred in connection with any health care services provided to prisoners inside and outside the jail" and pays the company "a set price based on average daily prisoner population."
The plaintiffs contend that this structure gives Wellpath an economic incentive to provide inadequate care and withhold needed medical services. Because it is paid a fixed price and must fund all health care costs, Wellpath allegedly withholds needed care on a routine basis.
U.S. Magistrate Judge Jacqueline Scott Corley found that the "plaintiffs have adequately alleged a policy of financial incentives to reduce costs of medical care in deliberate indifference to prisoners' serious medical needs."
Moreover, the plaintiffs provided concrete examples of how that policy resulted in deprivations of their constitutional rights.
The judge noted that the plaintiffs set forth numerous examples of inadequate care, including inmates being forced to share (pre-COVID) asthma inhalers, or (post-COVID) having their own inhaler but only being allowed to use it once a day at a prescribed time regardless of when it was needed.
The plaintiffs alleged that one inmate repeatedly asked to see an eye doctor but was denied because Wellpath did not have a staff ophthalmologist and would have had to pay for an exam as an out-of-pocket expense.
Another inmate with a diagnosis of cervical cancer allegedly was not able to get an evaluation until her lawyer got a court order compelling it.
The judge concluded that the plaintiffs had adequately alleged that Santa Rita prisoners are regularly denied necessary and appropriate outside medical care because the contract provides that the cost of such care comes out of Wellpath's profits.
The judge therefore denied the motion to dismiss the medical care counts of the complaint against the municipal defendants.
She set a case management conference for July 29 to discuss the next steps in the litigation.