Johnson v. Leonard, No. 18-1833 (8th Cir. 2019)
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Plaintiff, a pretrial detainee, filed suit against defendants under 42 U.S.C. 1983, alleging that defendants deprived him of dental care in violation of the Eighth Amendment. In this case, plaintiff suffered from multiple cavities and tooth pain. The district court ultimately granted summary judgment to defendants.
The Eighth Circuit affirmed, holding that the district court did not abuse its discretion in setting aside the entry of default against Defendant Collier where Collier had a meritorious defense and plaintiff was not significantly prejudiced. The court also held that plaintiff failed to meet the substantial evidentiary threshold required to show that the MEND Defendants and Collier were deliberately indifferent. In this case, defendants regularly responded to plaintiff's sick calls and followed protocol. Furthermore, any delay in permanently filling plaintiff's cavities did not show any unnecessary and wanton infliction of pain that was sufficiently harmful to evidence deliberate indifference to his serious medical needs.
Court Description: Benton, Author, with Gruender and Grasz, Circuit Judges] Civil case - Civil rights. In action by a pre-trial detainee alleging the jail's dental providers violated his Eighth Amendment rights through deliberate indifference to his his serious medical needs, the district court did not abuse its discretion in setting aside a default judgment against defendant Collier as Collier had a meritorious defense and the prejudice to plaintiff from the untimely filing of an answer was not significant; plaintiff's intent to appeal the summary judgment order in the case - based on his appeal of the subsequent judgment - was sufficient to preserve the order for appeal; the record showed defendants regularly responded to plaintiff's sick-calls, followed their company's protocol and prescribed pain medication and other appropriate treatment, and the district court did not err in granting them summary judgment on plaintiff's Eighth Amendment medical needs claims; delays in permanently filling plaintiff's cavities did not show the kind of unnecessary and wanton infliction of pain that is sufficiently harmful to establish deliberate indifference to serious medical needs.
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