Darnell Williams v. Joseph Macut
677 F. App'x 40
| 3rd Cir. | 2017Background
- Plaintiff Darnell Williams, a Pennsylvania inmate, sued under 42 U.S.C. § 1983 alleging Eighth Amendment and Equal Protection violations arising from treatment of an injured left ring finger.
- He alleged Defendants (Dr. Joseph D. Macut, PrimeCare Medical, and prison medical staff) misdiagnosed his injury, were negligent/reckless, and caused pain and suffering.
- Medical records attached to the complaint showed repeated medical encounters (initial visit June 3, 2013, and over a dozen visits in four months), examinations, x‑rays, and eventual surgery.
- The District Court dismissed the complaint for failure to state a claim and denied leave to amend; Williams appealed pro se and in forma pauperis.
- The Third Circuit considered whether Williams pleaded deliberate indifference (Eighth Amendment) or purposeful/irrational disparate treatment (Equal Protection) and reviewed dismissal de novo and denial of leave to amend for abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment — deliberate indifference to serious medical need | Williams contends misdiagnosis and denial of appropriate treatment/physical therapy caused undue suffering | Defendants contend they examined, treated, and eventually provided imaging and surgery; disagreement with treatment is not deliberate indifference | Dismissed — medical records show ongoing care; mere disagreement with treatment does not state deliberate indifference |
| Equal Protection — discriminatory treatment | Williams listed equal protection violation but pleaded no facts showing discrimination or protected-class status | Defendants argue no allegation of differential treatment or any comparator; no purposeful or irrational disparate treatment alleged | Dismissed — plaintiff failed to plead membership in a protected class or class-of-one disparate treatment |
| Sufficiency of pleading under Twombly/Iqbal | Williams argues his allegations are sufficient to proceed | Defendants argue allegations plus medical records show no plausible constitutional violation | Dismissed — complaint and records do not plausibly allege constitutional claims |
| Denial of leave to amend | Williams sought leave to amend (implicit on appeal) | Defendants contend amendment would be futile given the medical record and pleadings | Affirmed — denial of leave to amend not an abuse of discretion given the thorough treatment records |
Key Cases Cited
- Natale v. Camden Cty. Corr. Facility, 318 F.3d 575 (3d Cir. 2003) (deliberate indifference standard for prisoner medical claims)
- Monmouth Cty. Corr. Institutional Inmates v. Lanzaro, 834 F.2d 326 (3d Cir. 1987) (mere disagreement with treatment is not Eighth Amendment violation)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleading)
- Fleisher v. Standard Ins. Co., 679 F.3d 116 (3d Cir. 2012) (de novo review of dismissal under Rule 12(b)(6))
- Foglia v. Renal Ventures Mgmt., LLC, 754 F.3d 153 (3d Cir. 2014) (accept factual allegations as true on motion to dismiss)
- U.S. ex rel. Schumann v. Astrazeneca Pharm. L.P., 769 F.3d 837 (3d Cir. 2014) (standard for reviewing denial of leave to amend)
- Keenan v. City of Philadelphia, 983 F.2d 459 (3d Cir. 1992) (equal protection requires purposeful discrimination)
- Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir. 2008) (class-of-one equal protection framework)