Darrell Parks v. Andrew Edinger
663 F. App'x 124
| 3rd Cir. | 2016Background
- Darrell Parks, a federal prisoner formerly in USP Lewisburg's Special Management Unit (SMU), sued prison officials and medical staff alleging inadequate medical care for sarcoidosis and inadequate psychiatric care, and challenged his SMU placement.
- Defendants moved to dismiss or for summary judgment; the District Court granted summary judgment for defendants; Parks appealed.
- The District Court found Parks failed to exhaust administrative remedies for his sarcoidosis claim (no grievance regarding sarcoidosis) and thus that claim was procedurally defaulted.
- On the psychiatric/mental-health claim, the record showed ongoing evaluation and treatment; disagreement with diagnosis or treatment did not show deliberate indifference under the Eighth Amendment.
- On the SMU due-process claim, the court found no atypical and significant hardship compared to ordinary prison life and no evidence that SMU placement exacerbated Parks’s condition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of medical care for sarcoidosis | Parks contended he was denied adequate treatment for sarcoidosis | Defendants argued Parks did not exhaust administrative remedies and, on the merits, received appropriate care | The sarcoidosis claim was procedurally defaulted for failure to exhaust; alternatively, record shows adequate care |
| Adequacy of psychiatric/mental-health treatment (Eighth Amendment) | Parks claimed inadequate mental-health care and that SMU placement worsened his condition | Defendants showed consistent evaluation and treatment; disagreement with treatment is not deliberate indifference | Summary judgment for defendants: no deliberate indifference shown |
| Procedural due process for SMU placement | Parks alleged SMU placement violated due process and caused atypical and significant hardship | Defendants argued SMU placement did not impose atypical/significant hardship and conditions were not improper | Summary judgment for defendants: no protected liberty interest triggered; no atypical/significant hardship |
| Exposure to chemical munitions and respiratory treatment | Parks alleged exposure exacerbated asthma/sarcoidosis and officials were indifferent | Defendants presented evidence of treatment after exposures and no deliberate indifference | No evidence of deliberate indifference; treatment was provided |
Key Cases Cited
- Booth v. Churner, 532 U.S. 731 (2001) (exhaustion of administrative remedies required before filing § 1983/Bivens claim)
- Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment deliberate indifference standard for medical care)
- Sandin v. Conner, 515 U.S. 472 (1995) (liberty interest requires atypical and significant hardship relative to ordinary prison life)
- Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004) (prisoner exhaustion doctrine and exceptions)
- Giles v. Kearney, 571 F.3d 318 (3d Cir. 2009) (deliberate indifference defined as reckless disregard of substantial risk)
- United States ex rel. Walker v. Fayette County, 599 F.2d 573 (3d Cir. 1979) (disagreement with diagnosis/treatment does not establish deliberate indifference)
- Wiest v. Tyco Elecs. Corp., 812 F.3d 319 (3d Cir. 2016) (standard of review for summary judgment)