Saylor v. Randy Kohl, M.D., No. 14-3889 (8th Cir. 2016)
Annotate this CasePlaintiff, an inmate with PTSD, filed suit against defendants under 42 U.S.C. 1983, alleging violations of his constitutional rights because defendants were indifferent to his medical needs, and that defendants retaliated against him by transferring him to TSCI and by reclassifying him. In this interlocutory appeal, defendants challenged the district court's denial of summary judgment based on qualified immunity. In this case, the record shows that defendants met plaintiff's medical needs beyond the minimum standard required where they were aware of his medical needs and took steps to meet those needs. The court concluded that there was no deprivation of plaintiff's Eighth Amendment rights because plaintiff cannot show that defendants acted with deliberate indifference; plaintiff has no First Amendment claim because none of plaintiff's activities were protected and none of defendants' actions were retaliatory; and there is no cognizable Fourteenth Amendment claim because there has been no constitutional violation. Accordingly, the court reversed the judgment and dismissed the case.
Court Description: Beam, Author, with Riley, Chief Judge and Kelly, Circuit Judge] Prisoner case - Prisoner civil rights. The district court erred in finding the defendants were not entitled to qualified immunity on plaintiff's claims that they were deliberately indifferent to his serious medical needs in failing to properly treat him for Post-Traumatic Stress Disorder and that the level of care at the penitentiary was so low as to constitute cruel and unusual punishment; the supervisory defendants did not have a reason to believe (or actual knowledge) that the prison doctors and medical staff were mistreating or not treating plaintiff and cannot be held liable for cruel and unusual punishment in violation of the Eighth Amendment; the named medical defendants were not treating physicians and there was no evidence that they had personally violated plaintiff's rights or that they were responsible for a systemic condition which violated the Constitution; the evidence showed these defendants were aware of plaintiff's medical needs and took steps to meet them; there was no evidence these defendants retaliated against plaintiff in violation of his First Amendment rights or denied him his Fourteenth Amendment due process rights by transferring him to another comparable facility after he refused care from the psychiatrist at his current facility. Judge Kelly, dissenting.
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