Keandre Arnold v. Marts, et al.

Summary

The United States District Court for the Southern District of Indiana screens Keandre Arnold’s prisoner civil rights complaint under 28 U.S.C. § 1915A. The court dismisses claims against Mr. Lawson and Dr. Gaza, as well as certain claims concerning the initial suicide attempt, but allows Eighth Amendment excessive-force and deliberate-indifference claims to proceed against Sgts. Marts, Fish, and Surguy and Dr. Corvetta. The court directs service of process and terminates Mr. Lawson and Dr. Gaza as defendants.

Holdings

1. A § 1983 claim must be dismissed at screening when the complaint contains no factual allegations connecting the defendant to the alleged constitutional deprivation. The claim against Mr. Lawson was dismissed.
2. To state an Eighth Amendment deliberate-indifference claim, a prisoner must plausibly allege that the official actually knew of a substantial risk of serious harm and disregarded that risk by failing to take reasonable measures to stop it.
3. The claims against Dr. Gaza and Dr. Corvetta concerning Arnold's first attempted hanging with bed strings were dismissed because the allegations showed that the doctors responded by maintaining suicide-watch status and did not plausibly establish actual knowledge of an additional substantial risk beyond the incident to which they responded.
4. The claims against Dr. Gaza were dismissed because Arnold did not allege that Dr. Gaza was notified of the second hanging attempt or any other suicide attempt before Dr. Corvetta removed suicide watch.
5. The Eighth Amendment excessive-force claims against Sgts. Marts, Fish, and Surguy and the Eighth Amendment deliberate-indifference-to-medical-needs claims against Sgts. Marts, Fish, Surguy, and Dr. Corvetta may proceed.

Questions Presented

1. Whether the complaint stated a plausible Eighth Amendment excessive-force claim against Sgts. Marts, Fish, and Surguy.
2. Whether the complaint stated a plausible Eighth Amendment deliberate-indifference-to-medical-needs claim against Sgts. Marts, Fish, Surguy, and Dr. Corvetta.
3. Whether the complaint stated a claim against defendants against whom Arnold alleged no personal involvement or no facts showing actual knowledge of a substantial risk of serious harm.
4. Whether claims concerning the doctors' response to Arnold's first hanging attempt stated deliberate indifference rather than medical negligence.

Disposition

other