Noah Wright v. Laconya Harris, et al.

Summary

The United States District Court for the Eastern District of Arkansas adopts a partial recommended disposition with modifications in Noah Wright's civil rights action. The court permits an individual-capacity medical-deliberate-indifference claim against APN Seamster concerning refusal to provide an MRI for financial reasons, dismisses the other claims without prejudice, denies preliminary injunctive relief, and terminates several defendants.

Holdings

1. The retaliation claims failed at the screening stage because the complaint alleged no facts establishing a causal connection between the grievance and the cell search.
2. The complaint did not state a viable claim against Wellpath or viable official-capacity claims against Wellpath employees because the allegation of a policy or custom was a conclusory legal assertion unsupported by specific facts.
3. Plaintiff may proceed with his individual-capacity medical-deliberate-indifference claim against APN Seamster based on the alleged refusal to provide an MRI for financial reasons.
4. Plaintiff was not entitled to a preliminary injunction or temporary restraining order.

Questions Presented

1. Whether the retaliation claims stated a claim when the complaint lacked factual allegations showing a causal connection between Plaintiff's grievance and the cell search.
2. Whether the allegations that Wellpath and its employees maintained an unconstitutional policy or custom were sufficient to state a claim concerning the refusal to order an MRI.
3. Whether Plaintiff stated an individual-capacity medical-deliberate-indifference claim against APN Seamster based on the alleged refusal to provide an MRI for financial reasons.
4. Whether Plaintiff was entitled to a preliminary injunction or temporary restraining order.

Disposition

other