David Ayers v. Ryan Bohm, et al.

Summary

The court screened a pro se incarcerated plaintiff’s complaint alleging that jail officials and medical personnel violated his constitutional rights by discontinuing Suboxone and other medications and failing to treat withdrawal symptoms. The court held that the allegations did not state a federal claim because a physician prescribed alternative medications, most of which the plaintiff refused, and other defendants could defer to the physician’s medical judgment. The court dismissed the state-law claims without prejudice and granted 28 days to file an amended complaint.

Holdings

1. The complaint failed to state a constitutional medical-care claim because the allegations showed that Plaintiff was under the care of a physician who prescribed alternative medications, and Plaintiff voluntarily refused all but one of those medications.
2. The state-law claims were dismissed without prejudice because they could not proceed in this action without an underlying federal-law claim.

Questions Presented

1. Whether Plaintiff's allegations that jail personnel discontinued or failed to provide medications and ignored his withdrawal symptoms stated an objectively unreasonable medical-care claim under the Fourteenth Amendment.
2. Whether Plaintiff's refusal of prescribed alternative medications defeated or undermined his federal medical-care claim.
3. Whether the court could permit Plaintiff's state-law negligence claims to proceed in the absence of a viable federal claim.

Disposition

other