Leobardo Mercado v. Aramark Correctional Services, LLP, Centurion Health of Indiana, LLC, Tisch Thompson, Debra Hall, Ashly, Todd Shiefel, Dalton Albrecht, Dennis Reagle, Kyle McKinney, Cathleen Simone, Lori Fisher, S. Robbins, Nate Pulley, Brandon Pherson, Johnathan Jackson

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 Leobardo Mercado's Third Amended Complaint. The court held that Mercado plausibly alleged an Eighth Amendment Monell claim based on Centurion's practice of restricting access to medical care during prison lockdowns and that he adequately alleged serious medical needs, deliberate indifference, and causation.

Holdings

1. Mercado adequately pleaded an Eighth Amendment deliberate-indifference claim because he alleged objectively serious medical conditions and facts supporting an inference that Centurion deliberately restricted access to medical care despite knowing of those conditions.
2. Mercado adequately pleaded that Centurion's restriction of access to the medical wing during lockdowns constituted an express, de facto, or informal policy or practice and was the moving force behind the deprivation of medical care.
3. A Monell claim against an institutional medical-services provider may proceed even when the complaint does not allege that a particular individual medical provider separately violated the Eighth Amendment, so long as the institution's policy itself is plausibly alleged to be deliberately indifferent and to have caused the constitutional injury.

Questions Presented

1. Whether Mercado adequately pleaded an underlying Eighth Amendment violation based on deliberate indifference to objectively serious medical needs.
2. Whether Mercado adequately pleaded that Centurion had a policy, practice, or custom that was the moving force behind the alleged deprivation of medical care.
3. Whether a Monell claim against a private medical-services company may proceed at the pleading stage without alleging that an individual medical provider separately violated the Eighth Amendment.

Disposition

other