Teill Reynolds v. Mabel Adams, et al.

Summary

The United States District Court for the District of Kansas grants Defendants’ motion for summary judgment in a prisoner civil-rights action concerning medical treatment for Plaintiff Teill Reynolds’s fractured wrist. The court holds that Plaintiff failed to establish deliberate indifference under the Eighth Amendment against medical providers Mabel Adams and Dr. Bryan Wilson, including claims based on delayed care. The court declines to exercise supplemental jurisdiction over Plaintiff’s Kansas negligence and intentional-infliction-of-emotional-distress claims.

Holdings

1. A convicted inmate's medical-care claim is governed by the Eighth Amendment, not the Fourteenth Amendment, which applies to pretrial detainees; Reynolds's separate Fourteenth Amendment claim was foreclosed as a matter of law.
2. Adams was entitled to summary judgment because the evidence did not show that she knew of and disregarded an excessive risk to Reynolds's health or safety. Her direction that Reynolds use the nonemergency sick-call process, based on her understanding of the prison medical-care procedure and her belief that he was not in immediate distress, did not establish deliberate indifference.
3. Reynolds failed to show that the delay attributable to Adams caused substantial harm, such as lifelong handicap, permanent loss, or considerable pain, and therefore could not establish an Eighth Amendment violation.
4. Dr. Wilson was entitled to summary judgment because he did not refuse to treat Reynolds, stabilized the wrist, treated his pain, scheduled an x-ray for the next available date, and was not shown to have acted with deliberate indifference or to have caused substantial harm by not transferring Reynolds to a hospital immediately.
5. The court declined to exercise supplemental jurisdiction over the remaining Kansas-law negligence and intentional-infliction-of-emotional-distress claims and dismissed them without prejudice.

Questions Presented

1. Whether Adams was deliberately indifferent under the Eighth Amendment by initially denying Reynolds access to the emergency clinic and directing him to follow the nonemergency sick-call procedure.
2. Whether Adams's conduct caused substantial harm sufficient to support an Eighth Amendment delayed-medical-care claim.
3. Whether Dr. Wilson was deliberately indifferent under the Eighth Amendment by treating and splinting Reynolds's wrist at the prison, rather than transferring him to a hospital for an immediate x-ray and surgery.
4. Whether Reynolds could maintain a separate deliberate-indifference claim under the Fourteenth Amendment when he was a convicted inmate rather than a pretrial detainee.
5. Whether the court should exercise supplemental jurisdiction over Reynolds's Kansas-law negligence and intentional-infliction-of-emotional-distress claims after resolving all federal claims.

Disposition

other