Summary
The United States Court of Appeals for the Eighth Circuit affirmed the dismissal of Nuuh Amir Na’im’s unexhausted claims concerning alleged delays in medical care and affirmed summary judgment for the defendants on his claim regarding treatment of his dislocated finger. The court held that Na’im did not properly exhaust claims against Dr. Beck and Nurse Nunag for the alleged delays under the prison’s grievance policy. It further held that the evidence did not support a finding of deliberate indifference under the Eighth Amendment regarding the care provided on May 19, 2021.
Topics
Practice areas
Questions Presented
- Whether Na’im properly exhausted claims against Beck and Nunag based on an alleged delay in care between May 12 and May 19.
- Whether Na’im properly exhausted a claim against Beck and Nunag based on an alleged delay between May 19 and June 24.
- Whether the record supported an Eighth Amendment deliberate-indifference claim based on Beck and Nunag’s treatment of Na’im on May 19.
Holdings
- Na’im did not properly exhaust a claim against Beck and Nunag for an alleged delay in medical care between May 12 and May 19 because he did not identify them as the individuals allegedly responsible for the delay, and prison officials did not address their alleged responsibility on the merits.
- Na’im did not exhaust a claim against Beck and Nunag based on an alleged delay between May 19 and June 24 because that issue was not raised in the step-one or step-two grievances and was not decided on the merits at the final grievance stage.
- Summary judgment for Beck and Nunag was proper because no reasonable jury could find that they were deliberately indifferent to Na’im’s serious medical need on May 19.
Key quotations
“We conclude that Na’im failed to exhaust a claim against Beck and Nunag for alleged delay because he did not name them as persons who allegedly violated his rights by causing delay.” (-5)
“No reasonable jury could find Beck and Nunag were deliberately indifferent to Na’im’s serious medical need on May 19.” (-8)
Factual background
Na’im, an Arkansas inmate, dislocated his right pinky finger while playing basketball on May 12, 2021. Prison medical staff splinted the finger, provided pain medication, obtained an x-ray, and saw him on May 19, when Beck and Nunag attempted unsuccessfully to realign the finger, treated his pain, splinted it, and requested an orthopedic consultation. He later saw an orthopedic surgeon, who reset the finger on June 24. Na’im’s grievances complained of delays and treatment but did not identify Beck and Nunag as responsible for the alleged delays.
Procedural history
Na’im sued Arkansas prison medical staff under the Eighth Amendment, alleging deliberate indifference to his dislocated finger. The district court dismissed his delay-of-care claims for failure to properly exhaust administrative remedies and granted summary judgment to Beck and Nunag on the claim concerning treatment provided on May 19. Na’im appealed only the dismissal of his claims against Beck and Nunag, and the Eighth Circuit affirmed.