Al-Turki v. Robinson, 2014 U.S. App. LEXIS 15407

Plaintiff Homaidan Al‑Turki, a Colorado prisoner with Type II diabetes, suffered sudden severe left‑side/abdominal pain on the evening of October 5, 2008, collapsed, vomited, and believed he was dying.
He repeatedly notified correctional officers and requested medical attention; Defendant Mary Robinson, the only medical staff on duty, refused to see him citing lateness and non‑emergency status and instructed staff to have him submit a written sick call request the next day.
The shift commander spoke with Robinson, who reiterated that the condition was not an emergency and expressed escape‑risk concerns about outside transfer.
Plaintiff lost consciousness or slept during the night; by morning his pain had lessened and he saw medical staff at 10:00 a.m., passing two small kidney stones during a preexisting appointment.
Medical testimony established kidney stones can cause very severe pain and that prompt treatment can reduce pain/duration; experts agreed the stones were not life‑threatening but the pain was substantial.
Procedural posture: interlocutory appeal from denial of qualified immunity to a prison nurse; district court denied immunity finding trial‑view facts sufficient to show deliberate indifference and that the law was clearly established.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether several hours of severe abdominal pain satisfy the objective Eighth Amendment deliberate‑indifference standard	Al‑Turki: hours of severe pain (collapse, vomiting, belief he was dying) and loss of timely care constitute "substantial harm"	Robinson: pain was from a relatively benign condition (kidney stones), lasted ~5 hours, and treatment would only shorten—not eliminate—pain, so not objectively serious	Court: Pain was "substantial" (significant suffering); facts (taken for plaintiff) meet the objective prong — affirmed district court
Whether Robinson is entitled to qualified immunity because the law was not clearly established	Al‑Turki: a medical professional who knowingly ignores recognizable symptoms potentially creating an emergency is on notice	Robinson: prior Tenth Circuit decisions involved longer pain or more serious conditions, so she could not foresee liability	Court: Law was clearly established (Self v. Crum); ignoring repeated severe‑pain complaints falls within established precedent — qualified immunity denied

Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to serious medical needs)
Farmer v. Brennan, 511 U.S. 825 (subjective deliberate indifference standard)
Mata v. Saiz, 427 F.3d 745 (Tenth Circuit on objective prong for serious medical need)
Oxendine v. Kaplan, 241 F.3d 1272 (diagnosed condition or obvious need; delay must cause substantial harm)
Garrett v. Stratman, 254 F.3d 946 (examples of substantial harm from delay)
Kikumura v. Osagie, 461 F.3d 1269 (pain during delay can satisfy objective prong)
Sealock v. Colorado, 218 F.3d 1205 (not every twinge of pain is actionable)
Morris v. Noe, 672 F.3d 1185 (standards for interlocutory qualified immunity review)
Johnson v. Jones, 515 U.S. 304 (limits on evidence considered in interlocutory appeals)
Self v. Crum, 439 F.3d 1227 (medical professional cannot completely deny care when symptoms could indicate emergency)
Holland v. Harrington, 268 F.3d 1179 (qualified‑immunity inquiry focuses on situation as confronted)
Williams v. Liefer, 491 F.3d 710 (existence of later‑verifying medical evidence cannot justify initial denial of care)