Brian Woodcock v. Correct Care Solutions, LLC
20-5170
| 6th Cir. | Jul 6, 2021Background
- This is a §1983 class action by ~1,200 Kentucky inmates with chronic Hepatitis C (HCV) challenging KDOC’s 2018 HCV Treatment Plan as constitutionally inadequate.
- DAAs (direct-acting antivirals) cure nearly all HCV infections but are expensive; KDOC’s plan prioritized DAA treatment by APRI fibrosis scores and other criteria rather than treating all infected inmates.
- The 2018 plan used opt-in intake testing, regular monitoring (labs/APRI) every 3–6 months, vaccinations, and allowed limited medical discretion for exceptions; some inmates were excluded by administrative disqualifiers.
- Plaintiffs alleged Eighth/Fourteenth Amendment deliberate indifference (and disability claims); the district court granted summary judgment for defendants, finding monitoring = adequate ongoing treatment and no deliberate indifference.
- On appeal the Sixth Circuit affirmed: it held monitoring/diagnostics under the plan constituted treatment and plaintiffs failed the objective prong of deliberate indifference; Judge Stranch concurred in part and dissented in part, arguing genuine factual disputes on adequacy and opt-in testing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mootness (2020 plan amendments) | 2020 changes (opt-out testing, some rule relaxations) don't moot class claims because core claim—refusal to treat all inmates with DAAs—remains | 2020 amendments cure the challenged practices and thus divest jurisdiction | Not moot: amendments did not resolve the central §1983 claim about refusing DAAs to all inmates |
| Objective prong: whether monitoring equals constitutionally adequate treatment | Monitoring alone is not treatment; withholding DAAs (the only curative therapy) exposes inmates to substantial risk of serious harm | Diagnostic monitoring, vaccination, and prioritized DAA allocation constitute ongoing medical treatment; plaintiffs received care and monitoring | Monitoring/diagnosis constituted treatment; plaintiffs failed to show the plan created a substantial risk of serious harm, so objective prong not met |
| Subjective prong: deliberate indifference (knowledge + conscious disregard) | Defendants knew risks and rationed DAAs for cost reasons, showing reckless disregard | Decisions reflect medical judgment and resource allocation, not conscious disregard | Court did not reach subjective prong because objective prong failed; summary judgment affirmed |
| Punitive damages availability | Plaintiffs sought punitive damages for alleged deliberate indifference | Defendants argued punitive damages unavailable to the certified Rule 23(b)(2) injunctive-relief class and absent a showing of intent/recklessness | Denied: no deliberate indifference shown and class was certified for injunctive relief only, so punitive damages unavailable |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate-indifference framework; diagnostic techniques can constitute treatment)
- Farmer v. Brennan, 511 U.S. 825 (1994) (prison official liable for deliberate indifference where inmate faces substantial risk of serious harm)
- Rhinehart v. Scutt, 894 F.3d 721 (6th Cir. 2018) (distinguishes no-treatment vs. ongoing-treatment standards for §1983 medical claims)
- Atkins v. Parker, 972 F.3d 734 (6th Cir. 2020) (recognizes HCV as objectively serious and discusses Eighth Amendment standards in HCV prison-care context)
- Comstock v. McCrary, 273 F.3d 693 (6th Cir. 2001) (deliberate indifference standard applied to prison medical claims)
- Ford v. County of Grand Traverse, 535 F.3d 483 (6th Cir. 2008) (definition of "substantial risk of serious harm" for objective component)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard)