Daniels v. Mandalaywala, 9:23-cv-00983

Plaintiff Robert Daniels, a former inmate in New York State custody, suffered from chronic pain due to conditions like diabetes and neuropathy.
Upon transfer to Franklin Correctional Facility in 2019, his effective pain medications (Gabapentin and Tylenol #3) were immediately discontinued without individualized assessment.
Defendant Dr. Priti Mandalaywala, aware of Plaintiff's chronic pain and previous effective treatments, declined to represcribe those medications, adhering to a Department of Corrections policy limiting drugs deemed to have abuse potential.
Plaintiff repeatedly reported ongoing, severe, and unmanaged pain; alternative medications prescribed were ineffective, and it took about a year for an administrative exception to permit Gabapentin again.
Plaintiff argues Defendants' adherence to the policy constituted deliberate indifference under the Eighth Amendment, causing him needless suffering.
Defendant moved to dismiss for failure to state a claim and on statute of limitations grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness under statute of limitations	Claims are timely due to continuing violation doctrine	Claims are time-barred; no timely acts alleged in furtherance of policy	Claim is timely; continuing violation doctrine applies
Eighth Amendment deliberate indifference	Defendant knowingly refused effective treatment due to policy, not medical judgment	Plaintiff merely disagrees with choice of treatment; some care was given, so no constitutional violation	Plaintiff plausibly alleges inadequate treatment rising to deliberate indifference
Role of DOCS pain medication policy	Policy led to denial of effective care without individualized assessment	Adherence to policy does not equal deliberate indifference if medical judgment applies	Adherence to non-medical, blanket policy rather than patient need constitutes plausible deliberate indifference
Continuity of prior care as constitutional requirement	Defendant should have continued effective treatments based on prior medical records, especially given policy’s arbitrary nature	DOCS physicians not required to follow prior treatments; disagreement, not indifference	Failure to address pain due to non-individualized policy may be constitutional violation

Estelle v. Gamble, 429 U.S. 97 (Supreme Court recognized Eighth Amendment requires adequate medical care for prisoners)
Chance v. Armstrong, 143 F.3d 698 (disagreement over treatment not enough, but knowledge of effective treatment withheld based on non-medical reasons may constitute deliberate indifference)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard—know of and disregard an excessive risk)
Salahuddin v. Goord, 467 F.3d 263 (standards for evaluating seriousness and adequacy of medical care under Eighth Amendment)
Brock v. Wright, 315 F.3d 158 (institutional policy rejecting effective medication may violate Eighth Amendment)
Shomo v. City of New York, 579 F.3d 176 (continuing violation doctrine applies to deliberate indifference claims)