Da’Nate Lowe v. Middaugh, et al.

Summary

The Southern District of Indiana screens and dismisses Da’nate Lowe’s prisoner civil-rights complaint concerning pain allegedly caused when a dentist numbed the wrong side of his mouth during a dental procedure. The court concludes that Lowe failed to allege a Monell claim against Centurion or deliberate indifference by Dr. Middaugh under the Eighth Amendment. The court permits Lowe to file an amended complaint by July 15, 2026.

Holdings

1. The complaint failed to state a claim against Centurion because Lowe did not allege that the incident resulted from a Centurion policy, practice, custom, or action by a final decisionmaker.
2. The complaint failed to state an Eighth Amendment medical-care claim because an alleged mistake in administering anesthetic, without allegations that Middaugh was subjectively aware of and deliberately disregarded a serious medical risk, was insufficient to establish deliberate indifference.
3. The court dismissed the complaint but allowed Lowe to file an amended complaint because amendment at this early stage would not necessarily be futile and justice favored an opportunity to correct the pleading.

Questions Presented

1. Whether the complaint stated a viable claim against Centurion under 42 U.S.C. § 1983 based on municipal-liability principles.
2. Whether the alleged administration of anesthetic on the wrong side of Lowe’s mouth stated an Eighth Amendment deliberate-indifference claim against Dr. Middaugh.
3. Whether Lowe should be allowed to amend his complaint after dismissal at the pleading-screening stage.

Disposition

other