Prisoner’s claims for inadequate medical care under the 8th Amendment fails as defendants did not act with a deliberate indifference to a serious medical need.
A Pennsylvania state prisoner filed suit under 42 U.S.C. § 1983 against numerous employees of the Clinton County Correctional Facility (CCCF) and SCI-Rockview alleging that he received inadequate medical care in violation of the 8th Amendment. The prisoner contended that he injured his left foot when a step collapsed at CCCF and that personnel at CCCF told him to treat it by icing it and keeping it elevated. The prisoner later received an x-ray while at SCI-Rockview, which revealed that his foot was broken, and participated in a videoconference with an outside orthopedic doctor, who advised that the break appeared to be healing and recommended that he not apply extreme force or pressure on his injured foot. The prisoner alleged that he should have received an x-ray earlier and that his treatment was otherwise inadequate. The court ruled that the dismissal of the plaintiff’s complaint was correct as the plaintiff’s allegations did not establish that the defendants acted with deliberate indifference to his medical needs. To the contrary, the court held that the plaintiff’s allegations established that he did receive medical care for his foot. The plaintiff’s disagreement with his treatment or the alleged inadequacy of treatment does not rise to the level of deliberate indifference.
Case Law Alert, 1st Quarter 2014