Compton v. McDuffie County Detention Center
1:13-cv-00105
S.D. Ga.Jan 17, 2014Background
- Plaintiff David Compton, an MCDC inmate, filed a 42 U.S.C. § 1983 complaint after slipping exiting a shower and injuring his hand.
- He was seen by Sgt. Simms the evening of the fall; she said she would call the nurse/doctor but did not; Plaintiff was held until a doctor returned a call.
- The next day a nurse examined Plaintiff, noted swelling and pain, consulted a doctor who ordered an x-ray; Plaintiff waited for the x-ray, received an ace bandage, and fashioned a splint.
- Plaintiff alleges Sgt. Crawford was deliberately indifferent by delaying the x-ray and Sgt. Simms was deliberately indifferent for failing to call the nurse immediately; he seeks monetary damages.
- Plaintiff’s amended complaint superseded the original; two previously named defendants (MCDC and Sheriff Marshall) were omitted in the amended complaint.
- The magistrate judge screened the amended complaint and recommended dismissal for failure to state an Eighth Amendment deliberate-indifference claim and dismissal of MCDC and Marshall as parties.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether delay in x-ray and initial nurse call rise to Eighth Amendment deliberate indifference | Compton: delay and failure to call nurse/doctor amounted to deliberate indifference to serious medical needs | Defendants: Plaintiff received prompt attention, later nursing exam, doctor consultation, and interim care (ace bandage); any delay was not deliberate indifference | Dismissed — delay and facts pled do not show objectively serious medical need or subjective deliberate indifference |
| Whether omissions in amended complaint require dismissal of previously named defendants | Compton: (no argument; he omitted them) | Defendants: procedural — amended complaint supersedes original so omitted parties should be dismissed | Dismissed — MCDC and Sheriff Marshall removed because not named or alleged in amended complaint |
| Whether the shower/conditions allegations state a conditions-of-confinement claim | Compton: mentions mold, inadequate cleaning supplies, non-slip pads contributed to fall | Defendants: such conditions do not show extreme deprivation required for constitutional claim | Not a separate claim — allegations insufficient to state a conditions-of-confinement violation |
| Whether complaint should be allowed to proceed despite pro se status | Compton: amended complaint filed after R&R; requests leave to amend | Defendants/Court: liberal construction for pro se but not a duty to rewrite pleadings | Dismissed with report recommending case closure — pro se status did not overcome substantive pleading deficiencies |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (frivolous-complaint standard)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must be facially plausible)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for factual content)
- Estelle v. Gamble, 429 U.S. 97 (medical malpractice vs. Eighth Amendment deliberate indifference)
- Hudson v. McMillian, 503 U.S. 1 (Eighth Amendment standards for cruel and unusual punishment)
- Hope v. Pelzer, 536 U.S. 730 (qualified immunity discussion; related to Hill analysis)
- Hill v. Dekalb Reg'l Youth Det. Ctr., 40 F.3d 1176 (serious medical need and delay analysis)
- Goebert v. Lee County, 510 F.3d 1312 (requirements for deliberate indifference claim)
- Farrow v. West, 320 F.3d 1235 (delay-in-treatment analysis)
- Pintado v. Miami-Dade Hous. Agency, 501 F.3d 1241 (amended complaint supersedes original)
- Lowery v. Ala. Power Co., 483 F.3d 1184 (same on superseding complaint)
- Campbell v. Sikes, 169 F.3d 1353 (medical malpractice not Eighth Amendment violation)
- Harris v. Thigpen, 941 F.2d 1495 (prison medical care need not be perfect)