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ARNOLD v. GEORGE HILL CORRECTIONAL FACILITY
2:10-cv-05090
E.D. Pa.
Jul 19, 2012
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Background

  • Pro se plaintiff Darren Arnold, a prisoner at GWHCF, sues Dr. Phillips and Dr. Pierce under §1983 for alleged denial of medical care.
  • Plaintiff alleges asthma, eczema, and suicidal thoughts; he repeatedly requested to see Phillips and Pierce in 2010.
  • Medical staff allegedly denied or did not respond to emergency medical requests and grievances regarding his conditions.
  • Plaintiff was placed on suicide watch in December 2010 after contacting this Court about his mental health needs.
  • The court granted a Rule 12(b)(6) motion to dismiss the claims against Phillips and Pierce with prejudice.
  • The opinion analyzes whether the alleged conduct constitutes deliberate indifference to serious medical needs under the Eighth Amendment.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Deliberate indifference to serious medical needs (asthma/eczema) Arnold argues denial of care for asthma and eczema showed deliberate indifference Phillips and Pierce argue failure to treat does not show a serious medical need Claims dismissed for lack of plausible serious medical need and deliberate indifference
Deliberate indifference to suicide risk Arnold contends staff knew of suicide risk and ignored it Phillips and Pierce did not have actual knowledge of suicide threats; no culpable state Claims dismissed; no plausible knowledge or deliberate indifference shown

Key Cases Cited

  • Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (establishes Eighth Amendment medical care standard)
  • Colburn v. Upper Darby Twp., 946 F.2d 1017 (3d Cir. 1991) (suicide risk requires particular vulnerability and knowledge plus indifference (Colburn II))
  • Colburn v. Upper Darby Twp., 838 F.2d 663 (3d Cir. 1988) (Colburn I establishes vulnerability/knowledge framework)
  • Tskonas v. Cicchi, 308 F. App’x 628 (3d Cir. 2009) (definition of serious medical need in prison)
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Case Details

Case Name: ARNOLD v. GEORGE HILL CORRECTIONAL FACILITY
Court Name: District Court, E.D. Pennsylvania
Date Published: Jul 19, 2012
Docket Number: 2:10-cv-05090
Court Abbreviation: E.D. Pa.