Case: Haldane v. Hammond
2:15-cv-01810 | U.S. District Court for the Western District of Washington
Filed Date: Nov. 17, 2015
Closed Date: 2019
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Case Summary
On November 17, 2015, four prisoners in Washington state brought a class action lawsuit against the state's Chief Medical Officer of the Department of Corrections (DOC) and the Secretary of the DOC under 42 U.S.C. § 1983 for allegedly arbitrarily withholding necessary medical care from patients with serious and painful medical conditions. The prisoners, who went untreated or under-treated for serious ailments, including kidney failure, kidney stones, hernia, and chronic and substantial pain, alleged that the denial of care while incarcerated constituted cruel and unusual punishment forbidden by the Eighth Amendment. The Washington DOC only administered direct medical care for "medically necessary" conditions. All others required approval by a Department of Corrections Care Review Committee (CRC) consisting of doctors and other medical professionals across the state. Of all petitions for care, about 60% were being denied by the CRC. And complaints of chronic and substantial pain were ignored.
The plaintiffs sought (1) a declaration that the Washington DOC's policies and practices governing the approval of medical care requests by DOC providers and outside specialists violate the Eighth Amendment; (2) a preliminary and permanent injunction restraining the DOC from denying, without reasonable medical justification, necessary care for class members' serious medical needs; and (3) reasonable attorney's fees. The plaintiffs also sought to certify the following class: "All current and future prisoners, incarcerated under the jurisdiction of the Washington Department of Corrections, whose access to necessary medical care has been denied, or will be subject to denial, under the Department’s policies and practices governing access to health care requiring prior approval."
Judge Richard A. Jones denied class certification on September 18, 2017, holding that the proposed class lacked the necessary commonality for class certification. The court found that the plaintiffs had "not adequately identified common policies and practices to show that Defendants were deliberately indifferent to inmates’ needs." The plaintiffs sought to appeal the decision, but the Ninth Circuit denied their petition to appeal on December 21, 2017.
The plaintiffs filed to amend the complaint in March 2018 to reflect a new Secretary of the DOC. Later in June 2018, the plaintiffs filed a motion to stay the proceedings of the case for six months while the parties tried to resolve the case. The motion stated that the DOC revised the Offender Health Plan. Days later, the court granted an order to dismiss one of the named plaintiffs and refused to stay the case, opting instead to vacate the trial date for six months. In December 2018, the court pushed the trial date even further, settling on September 2019.
On January 14, 2019, the court granted requests from two plaintiffs for dismissal, leaving only one remaining plaintiff. Three months later, in March 2019, the final plaintiff moved to terminate the case. The court granted the dismissal of the party and in turn closed the case on March 27, 2019 as no plaintiffs remained. It is unknown why the plaintiffs voluntarily dismissed and the case is now closed.
Summary Authors
Dan Hofman (2/18/2016)
Virginia Weeks (3/15/2018)
Richa Bijlani (11/25/2019)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4411716/parties/haldane-v-hammond-md/
Allen, Nicholas B. (Washington)
Balson, Hank L. (Washington)
Anderson, Austin W. (Washington)
Barbara, Scott M (Washington)
Brinckerhoff, Matthew D. (Washington)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/4411716/haldane-v-hammond-md/
Last updated March 31, 2026, 4:51 a.m.
Case Details
State / Territory:
Case Type(s):
Healthcare Access and Reproductive Issues
Special Collection(s):
Key Dates
Filing Date: Nov. 17, 2015
Closing Date: 2019
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Individuals incarcerated in the state of Washington who were denied certain kinds of medical diagnosis and treatment by the state Department of Corrections.
Plaintiff Type(s):
Attorney Organizations:
Columbia Legal Services (formerly Evergreen)
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Denied
Defendants
State
Chief Medical Officer
Secretary of Corrections
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Declaratory Judgment Act, 28 U.S.C. § 2201
Constitutional Clause(s):
Other Dockets:
Western District of Washington 2:15-cv-01810
Available Documents:
Outcome
Prevailing Party: Defendant
Relief Granted:
Source of Relief:
Form of Settlement:
Issues
General/Misc.:
Medical/Mental Health Care:
Case Summary of Haldane v. Hammond, Civil Rights Litig. Clearinghouse, http://www.dev.clearinghouse.net/case/15144/ (last updated 11/25/2019).