SAN FRANCISCO (CN) — A federal judge granted summary judgment to a jail health contractor Friday, finding inmates failed to link what they said was substandard care to save money to any policy or practice at the company.
Twelve inmates at Santa Rita Jail in Dublin, California, sued Wellpath Management, which provided primary care, specialty care and appropriate referrals to outside providers and specialties when medically necessary for Santa Rita inmates. They sued under the Monell doctrine, which allows an individual to hold a government agency responsible for violating their rights or causing harm.
U.S. District Judge Jacqueline Scott Corley, a Joe Biden appointee, heard arguments from inmates on Wednesday afternoon. The plaintiffs said Wellpath operates its program based on a practice of cost-cutting rather than providing constitutionally sound medical care in the jail. The plaintiffs argued Wellpath did not want to order culturing of wounds, MRIs or CT scans for Santa Rita inmates because it required outside referrals, which would cut into Wellpath’s profits.
In her 21-page ruling issued Friday, Corley found the plaintiffs had failed to prove that Wellpath’s conduct was caused by any official policy, culture or practice, which is integral to prove a Monell claim.
“To the extent plaintiffs’ experts opine the care provided to these plaintiffs on particular occasions fell below the standard of care, this is not the only relevant question. To prevail on their Monell claim, each plaintiff must prove both a constitutional violation occurred and the violation was caused by a Wellpath policy or custom,” Corley wrote. “Plaintiffs’ experts offer evidence of neither. Deliberate indifference requires more than the lack of due care — negligence is not enough. And, no expert opines the reason any plaintiff’s care fell below the standard of care was because of a Wellpath policy or practice.”
Corley also found the 12 individual plaintiffs’ experiences were too different to support any finding of a practice of Wellpath providing constitutionally deficient medical care, and that there were questions left unanswered that would make it difficult to rule in the plaintiffs’ favor.
“As the previous description of their claims shows, some plaintiffs experienced issues with dental care, others with mental health treatment, and still others with asthma, and so on. Further, plaintiffs offer no evidence as to the numbers of detainees Wellpath treated during the (undefined) period Wellpath was responsible for plaintiffs’ care,” Corley wrote. “Even if some pattern and practice could be found from such diverse circumstances, what percentage of detainees needing care received constitutionally deficient care? What providers were responsible for the deficient care? The record leaves these basic questions unanswered.”
Finally, Corley found the inmates failed to provide any evidence that Wellpath told any physician to delay or deny care because of cost factors, whether through testimony or patient medical records.
“Despite the many years this case has proceeded, and the considerable leeway the court has given plaintiffs, they have failed to identify evidence sufficient to support a finding in any plaintiff’s favor on the Monell claim. While the evidence plaintiffs have proffered might have created a dispute of fact as to whether the care they were provided on particular occasions fell below the standard of care, that is not the claim they brought,” Corley wrote. “Since they have failed to offer evidence that supports a finding a Wellpath custom or policy or pattern and practice was the moving force behind any Plaintiff’s challenged individual treatment decisions, Wellpath’s motion for summary judgment must be granted.”
The plaintiffs originally sued in 2019, claiming the kitchen at the jail was overrun with pests contaminating their food. Corley denied their request for a preliminary injunction in 2021, noting that the county had taken steps to eliminate pest problems in the kitchen.
The plaintiffs then amended their complaint, adding the claims about substandard medical care.
Attorneys for the inmates and Wellpath did not respond to requests for comment by press time.