Medical Development International v. California Department of Corrections & Rehabilitation

A receiver appointed by a federal district court currently oversees the delivery of medical care to prisoners incarcerated by the California Department of Corrections and Rehabilitation (CDCR). Medical Development International (MDI) provided medical services for two of CDCR’s prisons, without a finalized contract. The Receiver terminated MDI’s services. MDI was not paid for much of its work and filed suit against the Receiver and CDCR. MDI’s claim has been before two different federal district courts, but MDI did not obtain relief from either of them. Appeals have been taken by MDI from both and have been consolidated before us.

The primary question presented to us is whether the Receiver is immune from suit for MDI’s claim. We conclude that in the circumstances presented here the Receiver may be sued in his official capacity and he is not covered by judicial immunity. We also conclude that the federal district court had subject matter jurisdiction over MDI’s lawsuit after it was removed from state court, and that MDI was not required to obtain permission from the court that appointed the Receiver prior to filing suit against him, under 28 U.S.C. § 959 (a). As a result, we…