Larry Warren v. Aramark Correctional Services, LLP, et al.

Summary

The United States District Court for the Southern District of Indiana denied Centurion Health of Indiana, LLC's Rule 12(b)(6) motion to dismiss. The court held that Larry Warren plausibly alleged an Eighth Amendment Monell claim based on a practice of restricting access to medical care during prison lockdowns. The court also held that Warren adequately pleaded an Indiana intentional infliction of emotional distress claim.

Holdings

1. The amended complaint plausibly alleged objectively serious medical needs and deliberate indifference based on allegations that Centurion and associated defendants knowingly restricted access to medical care for months, including for punitive and concealment purposes.
2. Warren adequately alleged that Centurion maintained or participated in a policy, practice, or custom of restricting access to the medical wing during lockdowns and that the restriction was the moving force behind the alleged deprivation of medical care.
3. The amended complaint plausibly alleged an IIED claim by asserting that Centurion intentionally or recklessly engaged in extreme and outrageous conduct by depriving incarcerated persons of medical care for punitive and concealment purposes, causing severe emotional distress.
4. Indiana does not require a plaintiff to plead direct physical impact to sustain an IIED claim.

Questions Presented

1. Whether Warren plausibly alleged an underlying Eighth Amendment violation sufficient to support a Monell claim against Centurion without identifying an individual medical provider who was deliberately indifferent.
2. Whether Warren plausibly alleged that a Centurion policy, practice, or custom restricting access to the medical wing during lockdowns was the moving force behind the alleged constitutional deprivation.
3. Whether Warren's amended complaint plausibly alleged an Indiana intentional-infliction-of-emotional-distress claim.
4. Whether Indiana law requires a plaintiff to plead direct physical impact to maintain an intentional-infliction-of-emotional-distress claim.

Disposition

other