Dadd v. Anoka County, No. 15-2482 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit against Anoka under 42 U.S.C. 1983, alleging that defendants were deliberately indifferent to his serious medical needs in violation of his substantive due process rights under the Fourteenth Amendment while he was in custody at the county jail. The district court denied Anoka's Rule 12(b)(6) motion to dismiss the complaint based on qualified immunity. In this case, plaintiff arrived at the jail with instructions from his doctor in the form of a Vicodin prescription, and the deputies and the jail nurse ignored his complaints of pain and requests for treatment. When plaintiff was prescribed additional medication by a jail doctor, he did not receive it. Moreover, defendants had fair warning about the unconstitutionality of a failure to provide pain medication for serious dental conditions in particular. Accordingly, the court affirmed the judgment of the district court denying defendants qualified immunity. The court declined to impose sanctions.
Court Description: Kelly, Author, with Beam and Shepherd, Circuit Judges] Prisoner case - Prisoner civil rights. In this action alleging the county and its jailers and jail medical staff were deliberately indifferent to plaintiff's medical needs, the district court did not err in denying defendants' Rule 12(b)(6) motion to dismiss the complaint on the basis of qualified immunity as plaintiff showed he was suffering from a serious dental problem and that the defendants were aware of his condition and deliberately refused to provide him with pain medication which had been prescribed for him and brought to the jail at the time of his arrest; defendant had fair warning about the unconstitutionality of a failure to provide pain medication for prisoners with serious dental conditions; defendants' appeal was not frivolous and damages for a frivolous appeal would not be awarded.
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