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Jackson v. Bland

United States District Court, E.D. Arkansas, Pine Bluff Division

January 5, 2017



         I. Background

         In this lawsuit, Michael Jackson, an Arkansas Department of Correction (“ADC”) inmate, claims that Defendants acted with deliberate indifference to his serious medical needs. (Docket entry #2) Because Mr. Jackson did not attribute any unconstitutional conduct to either Defendant Drummond or Defendant Griffin in his original complaint, the Court instructed him to file an amended complaint to further explain his constitutional claims against those Defendants. (#4) After Mr. Jackson filed his amended complaint, the Court determined that he had stated deliberate-indifference claims against Defendants Bland, Drummond, and Griffin. (#6)

         Defendant Griffin, whose only involvement was responding to Mr. Jackson's grievances, moved for dismissal. (#13) The Court granted Defendant Griffin's motion. (#22) Defendants Bland and Drummond have now moved for summary judgment. (#33) Mr. Jackson has also moved for summary judgment. (#39) The Defendants have responded to Mr. Jackson's motion for summary judgment. (#40) The Court will consider Mr. Jackson's motion for summary judgment as both a motion and as a response to the Defendants' motion for summary judgment.

         II. Analysis

         A. Standard

         Summary judgment is appropriate only when the evidence, viewed in the light most favorable to the nonmoving party, shows that there is no real dispute about the facts that are important to the outcome of the case. Fed.R.Civ.P. 56; Celotex Corp. v. Catrett, 477 U.S. 317, 322-23, 106 S.Ct. 2548 (1986); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 246, 106 S.Ct. 2505 (1986). The moving party bears the burden of proving that all important facts are undisputed. Once the moving party has come forward with evidence showing that all material facts are undisputed, the responding party must meet proof with proof.

         B. Deliberate-Indifference Standard

         Deliberate indifference to a prisoner's serious medical needs constitutes the unnecessary and wanton infliction of pain and is prohibited by the Eighth Amendment to the United States Constitution. McRaven v. Sanders, 577 F.3d 974, 979 (8th Cir. 2009); Estelle v. Gamble, 429 U.S. 97, 104 (1976). To prove a deliberate-indifference claim, a plaintiff must plead facts showing that he suffered from an objectively serious medical need and that the defendants knew of the need, yet deliberately disregarded it. Hartsfield v. Colburn, 371 F.3d 454, 457 (8th Cir. 2004). In this context, a “serious medical need” is one that has been diagnosed by a doctor as requiring treatment, or a need that is so apparent that a layperson would easily recognize the need for a doctor's attention. Coleman v. Rahija, 114 F.3d 778, 784 (8th Cir. 1997).

         Defendants can be held liable only if they “actually knew of but deliberately disregarded” an inmate's serious medical need. Id. This showing requires a mental state “akin to criminal recklessness.” Id. (quoting Gordon v. Frank, 454 F.3d 858, 862 (8th Cir. 2006)). This means that Mr. Jackson must show “more than negligence, more even than gross negligence.” Fourte, 746 F.3d at 387 (quoting Jolly v. Knudsen, 205 F.3d 1094, 1096 (8th Cir. 2000)). Stated another way, to prevail on this claim, Mr. Jackson must show that the Defendants' actions were “so inappropriate as to evidence intentional maltreatment or a refusal to provide essential care.” Dulany v. Carnahan, 132 F.3d 1234, 1240-41 (8th Cir. 1997).

         C. Mr. Jackson's Motion for Summary Judgment

         In his motion for summary judgment, Mr. Jackson argues that the Defendants should be found liable as a matter of law for failing to adequately treat him for swelling and pain in his knees, primarily his right knee. Mr. Jackson apparently has had swelling and pain in his knees since mid-2013. His complaint in this lawsuit, however, concerns treatment beginning on April 16, 2015, when he went to the infirmary complaining of bilateral leg swelling and pain. He alleges that the Defendants' treatment did not resolve the problem with his legs, and he believes Defendants have missed the mark by failing to focus on his circulatory problems.

         In support of his motion, Mr. Jackson notes that he was issued “special medical authorizations” on June 25, 2016. He invites the Court to infer that the Defendants issued the special authorizations only after he filed this lawsuit, that is, after months of providing “meaningless medical care.” He concedes, however, that this latest treatment “has not helped” either.

         The medical records show that Mr. Jackson has received medical care for swollen knees and knee pain since the problem first developed, in mid-2013. The Court declines to penalize Defendants for continuing to address Mr. Jackson's knee problems after the lawsuit was filed. The issue here is whether Defendants' treatment of Mr. Jackson's knee problems during the relevant time rose ...

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