Parsons v. Ryan

Arizona inmates, including Victor Parsons, (inmates) (plaintiffs) filed a lawsuit for injunctive and declaratory relief against Arizona Department of Corrections’s (ADC) director Charles Ryan (defendant), alleging that ADC employed statewide healthcare policies and practices that exposed the inmates to a substantial risk of harm and that the ADC was deliberately indifferent to that harm in violation of the Eighth Amendment to the United States Constitution. Arizona law required ADC to provide healthcare services to all state inmates. The inmates alleged, among other things, that ADC failed to provide adequate medical staff and emergency treatment, denied necessary medical care and medications, provided insufficient and substandard dental care, and did not provide treatment or medication for mentally ill inmates. The inmates moved to certify a class of inmates challenging ADC’s healthcare policies and practices and a subclass of inmates challenging ADC’s isolation-unit policies and practices. ADC opposed the motion, arguing that class certification was inappropriate under Federal Rule of Civil Procedure (FRCP) 23(b)(2) because the proposed class and subclass members were affected by ADC’s allegedly harmful policies in different ways and that those alleged harms could be redressed only with individualized remedies. The district court certified the class and subclass, finding that the inmates’ claims satisfied the requirements of FRCP 23(b)(2) because they involved policies that affected all inmates and because injunctive relief changing those policies would provide an appropriate remedy by improving services for all inmates.