Mead v. Palmer, No. 14-1680 (8th Cir. 2015)
Annotate this CaseMead, committed to Iowa's Civil Commitment Unit for Sex Offenders filed a 42 U.S.C. 1983 complaint alleging that defendants deprived him of "extensive dental care that he is unable to afford" and were "deliberately indifferent to [his] need for dental care." He alleged that he had many teeth pulled while in custody, was unable to chew food properly, suffered from acid reflux, and had become diabetic. The defendants moved for summary judgment arguing that Mead had sufficient funds to pay for a partial denture plate and failed to demonstrate a serious medical need because he had not requested and did not want a soft diet, had not lost weight, had complained of discomfort but not pain, had stated that he was satisfied with his medical care, and no dentist had concluded that Mead had a serious medical need for dentures. The defendants argued that they were entitled to qualified immunity, not personally responsible for Mead's alleged damages, and immune from money damages. The district court denied summary judgment, concluding that Mead had established genuine issues of material fact. The Eighth Circuit reversed, finding the defendants entitled to qualified immunity from damages on Mead's claim regarding the denial of partial dentures
Court Description: Smith, Author, with Bye, Circuit Judge, and Schiltz, District Judge] Civil case - Civil rights. The district court erred in denying defendants' motion for summary judgment based on qualified immunity on plaintiff's claim for damages regarding the denial of partial dentures; the evidence showed plaintiff, a civilly-committed patient, had received regular dental exams which did not show a partial denture was medically necessary, was able to eat, had gained weight, was not in pain and had rejected alternative diets. Judge Bye, dissenting.
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