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