East v. Minnehaha County, No. 19-2621 (8th Cir. 2021)
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Plaintiff filed suit against the County, CCS, and other prison officials and healthcare providers under 42 U.S.C. 1983, alleging deliberate indifference to his serious medical needs in violation of the Fourteenth and Eighth Amendments. Plaintiff also alleges that two officers threatened him in violation of the Eighth Amendment. Plaintiff's allegations stemmed from complications resulting from treatment of his foot injuries.
The Eighth Circuit affirmed the district court's grant of one defendant's motion to dismiss and summary judgment as to the other defendants. The court held that the district court properly granted the physician assistant's motion to dismiss where the amended complaint failed to sufficiently allege that the physician assistant knew that plaintiff had serious medical needs and was deliberately indifferent to them. In this case, the court accepted plaintiff's allegations as true, but not his legal conclusions. The court also held that the district court properly granted summary judgment on plaintiff's deliberate indifference claims as to the remaining defendants where plaintiff's claims are a mere disagreement with treatment decisions. The court further held that plaintiff failed to administratively exhaust his claims that prison guards threatened retaliation, and plaintiff cannot show that a reasonable inmate of ordinary firmness would have failed to file a grievance in his situation.
Court Description: [Benton, Author, with Shepherd, and Kelly, Circuit Judges] Prisoner case - Prisoner civil rights. No error in dismissing case against physician assistant Adams as the allegations in the complaint failed to state any facts to sustain its conclusory statements; the County, the medical care providers and other staff were properly granted summary judgment on plaintiff's claims of deliberate indifference as the claims amounted to no more than a disagreement with treatment decision which did not approach criminal recklessness; claims regarding threats from guards had not been administratively exhausted and plaintff's argument that he was not required to exhaust because of fear or intimidation failed because he could not show that a reasonable inmate of ordinary firmness would have failed to file a grievance in his situation. [ January 25, 2021 ]
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