Danny R. Richards v. Ind. Dept. of Corrs., et al.

Summary

The court deferred ruling on Danny R. Richards’s motion for a preliminary injunction seeking restroom access accommodations and a gastroenterology consultation while incarcerated. The court found that additional information was needed regarding the effectiveness of the defendants’ restroom-access accommodation and the medical reasons for denying or not addressing Richards’s requests. The court denied requests for Neurontin, a disability designation, and an inference regarding inadequate medical treatment, and set deadlines for supplemental responses and a reply.

Holdings

1. The court did not decide whether the defendants' proposed accommodation was legally reasonable because the record lacked sufficient information about how often Richards needed restroom access and how often staff refused or delayed requests to unlock his cell door. The court deferred ruling and ordered additional factual submissions.
2. The court deferred ruling on Richards's request for a gastroenterology consultation because, although his showing did not establish a constitutional entitlement to that consultation, his allegations suggested possible deliberate indifference and the defendants had not provided medical reasons for refusing or failing to address his requests.
3. Richards was not entitled to a preliminary injunction requiring medical staff to place him back on Neurontin because he provided insufficient facts showing a serious medical need, deliberate indifference, or irreparable harm.
4. Richards was not entitled to a preliminary injunction requiring Centurion and the Indiana Department of Corrections to designate him as disabled because the requested designation did not appear to arise from the claims in this case and, standing alone, did not constitute medical treatment or an ADA/Rehabilitation Act accommodation.

Questions Presented

1. Whether Richards was entitled at this stage to a preliminary injunction requiring defendants to keep his cell door open or otherwise provide restroom access during recreation under the ADA and Rehabilitation Act.
2. Whether Richards was entitled at this stage to a preliminary injunction requiring an immediate gastroenterology consultation under the Eighth Amendment.
3. Whether Richards was entitled to an order requiring Centurion and the Indiana Department of Corrections to designate him as disabled.
4. Whether the court should infer from defendants' preliminary-injunction briefing that Richards was not receiving treatment for all of his serious medical needs.

Disposition

other