Case Explained: BROWN V. NGUYEN, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-26 Docket: 3:23-cv-00593-WHO The Ninth Circuit affirmed the district court’s summary judgment and dismissal order in Gregory L. Brown’s pro se civil rights action brought under 42 U.S.C. § 1983, which alleged violations of his Eighth Amendment right to be free from cruel and unusual punishment regarding medical treatment and conditions of confinement. Regarding the Eighth Amendment claim against Dr. Nguyen for inadequate treatment of back pain, the court held that summary judgment was proper because Brown failed to raise a genuine dispute of material fact regarding deliberate indifference. Applying the standard set forth in *Toguchi v. Chung*, the court noted that a mere difference of opinion between a plaintiff and a doctor is insufficient; Brown failed to show that the medical care provided was “medically unacceptable” or chosen in conscious disregard of an excessive risk to his health. Regarding claims against various correctional officers, the court affirmed their dismissal for failure to state a plausible claim under *Hebbe v. Pliler*. The court applied the standard requiring that risks of future harm be “sure or very likely to cause serious illness and needless suffering” with “sufficiently imminent dangers.” Furthermore, the court found no liability for the officers because they were not integral participants in any constitutional violation, noting that supervisors cannot be held vicariously liable under § 1983 for subordinates’ actions absent specific involvement. The court also affirmed the dismissal without prejudice of claims against defendants Eldridge, Michels, Navarro, Williams, and Vang due to misjoinder under Federal Rule of Civil Procedure 20(a)(2), as their alleged conduct did not arise from the same transaction or series of occurrences as the rest of the action. As a practical consequence, the judgment of the district court is affirmed, meaning Brown’s lawsuit against all named defendants remains dismissed and he receives no relief on these claims. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.