Turner v. Mull, No. 14-1589 (8th Cir. 2015)
Annotate this CaseTurner, a Missouri inmate, suffered from a neurological disorder but was able to ambulate, stand, and sit by using leg braces and crutches. Although Turner received medical care several times, no physician ordered a wheelchair or transport by wheelchair-accessible van. The facility had a wheelchair-accessible van with a "lift," but restricted its use to wheelchair users. Signage on the van advised that only wheelchairs were allowed on the lift and that standing on it was forbidden to avoid falls. For transport to a medical appointment, Turner arrived with neither a wheelchair nor a physician's order to use a wheelchair-accessible van. Turner alleges that he had to enter the van by crawling; that urine and vomit were on its floor, so that he was unable to eat while traveling; and that, during his return trip the driver stopped near a bridge and stated that the guards could drown Turner and claim that Turner tried to escape., Turner filed an Inmate Resolution Request; according to Turner, prison staff "ransacked" his cell and were verbally abusive in retaliation and that when he was moved to another prison, he was transported in a non-wheelchair-accessible van for part of the trip. The Eighth Circuit affirmed rejection of Turner’s claims of violations the Eighth and Fourteenth Amendments; the Americans with Disabilities Act,, 42 U.S.C. 12131; and the Rehabilitation Act, 29 U.S.C. 794.
Court Description: Smith, Author, with Benton and Shepherd, Circuit Judges] Civil Case - prisoner civil rights. Turner, who suffers form a neurological disorder but able to ambulate, stand and sit with use of leg braces and crutches, claimed prison officials were deliberately indifferent to his serious medical needs by transporting him in a non-wheelchair-accessible van, threatening him, and retaliating against him for complaining. District court?s grant of summary judgment to defendants is affirmed, as Turner was not entitled to a wheelchair-accessible van absent a doctor?s order and use of a wheelchair. The official capacity and individual capacity claims failed because he failed to show he had an objectively serious medical need requiring use of a wheelchair-accessible van; the conditions claim did not rise to a constitutional violation; the threat claim did not result in injury; and the retaliation claim failed for lack of evidence of a causal link between his complaint and any adverse action. The district court did not err in holding qualified immunity barred the claims against defendants.
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