Ryan Christopher Cheatham v. Andrew Dedeke, et al.

Summary

The United States District Court for the District of Kansas granted summary judgment to jail employees in Ryan Cheatham’s 42 U.S.C. § 1983 deliberate-indifference claim concerning treatment and proposed surgery for a finger injury. The court held that Cheatham failed to properly exhaust available administrative remedies and, alternatively, failed to show a constitutional violation under the applicable deliberate-indifference standard. Cheatham’s motion for summary judgment was denied, and his motion for an order was denied as moot.

Holdings

1. Cheatham failed to exhaust available administrative remedies because he did not appeal his grievances to the Jail Commander as required by the Leavenworth County jail grievance procedure.
2. The defendants were entitled to qualified immunity because Cheatham did not produce evidence that their conduct violated the Constitution; therefore, the court did not need to decide whether the right was clearly established.
3. Cheatham was not entitled to summary judgment because the evidence did not establish deliberate indifference and instead showed repeated medical evaluations and treatment.

Questions Presented

1. Whether Cheatham exhausted all available administrative remedies before bringing his § 1983 claim concerning medical care at the jail.
2. Whether the defendants were entitled to qualified immunity because the evidence did not establish a constitutional violation for deliberate indifference to a serious medical need.
3. Whether Cheatham was entitled to summary judgment on his deliberate-indifference claim.

Disposition

other