Pride v. Correa

A California prisoner's claim for injunctive relief is not barred by a pending class action if he brings the claim for relief solely on his own behalf.

David Pride, a California state prisoner, received treatment from Dr. Santiago, the prison doctor at Calipatria State Prison. Dr. Santiago proscribed knee braces and a special mattress for Pride’s injuries. The committee reviewing the prescription denied Pride’s treatment. Under 42 U.S.C. § 1983, Pride filed a pro se complaint against two of the committee members, claiming that the committee improperly denied him medical treatment in violation of his Eighth Amendment rights. The committee members filed a Fed. R. Civ. Pro. 12(b)(6) motion for dismissal on the grounds that an ongoing class-action lawsuit, Plata v. Brown, kept Pride's claim for injunctive relief from being brought independently. The district court construed the motion as a Rule 12(b)(1) motion, granted it, and dismissed the claim for injunctive relief. Pride appealed, and the Ninth Circuit held that the district court erred in granting the motion for dismissal. Pride's claim was limited to denial of medical care on his own behalf, and was therefore not duplicative of the relief sought in the Plata class action. The panel did not determine whether Pride’s claim was moot as to the Chief Medical Officer that transferred to another prison. REVERSED and REMANDED.