Godsey v. Parker, 3:18-cv-00288

Plaintiff Joseph Godsey, a Tennessee inmate proceeding pro se, sued medical staff at Hardeman County Correctional Facility under 42 U.S.C. § 1983 alleging medical malpractice and negligence for failing to timely diagnose a liver condition.
In April 2017 Godsey complained of side and back pain; a nurse practitioner diagnosed edema, performed blood work said to be fine, and recommended a multivitamin and reduced salt intake.
Godsey’s pain worsened; he sought sick call again and was told prior blood work remained normal.
In April 2018, after transfer to another TDOC facility, new blood work showed liver enzymes four times normal; a physician said the prior facility should have detected the issue earlier.
Godsey sought monetary damages for the alleged malpractice/negligence of Hardeman County medical staff.
The district court screened the complaint under the PLRA and Iqbal/Twombly standards and dismissed it for failure to state an Eighth Amendment § 1983 claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether alleged failure to diagnose and treat a liver condition rises to an Eighth Amendment deliberate indifference claim	Godsey contends earlier providers were medically negligent and should have discovered elevated liver enzymes sooner	Medical staff provided examinations and blood work; any shortcomings amount to negligence/medical malpractice, not constitutional indifference	Dismissed: allegations sound only in negligence/medical malpractice and do not meet the deliberate indifference standard required for an Eighth Amendment § 1983 claim
Whether complaint survives PLRA screening under Iqbal/Twombly	Godsey argues factual allegations show harm from delayed diagnosis	Defendants argue the pleadings lack allegations of subjective intent or recklessness necessary for constitutional claim	Court held pleadings insufficiently plausible to show the mental state required for deliberate indifference and thus fail § 1915 screening

Ashcroft v. Iqbal, 556 U.S. 662 (pleading must state a plausible claim to survive screening)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
Estelle v. Gamble, 429 U.S. 97 (medical malpractice is not a per se Eighth Amendment violation)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference requires subjective culpability akin to criminal recklessness)
Santiago v. Ringle, 734 F.3d 585 (Sixth Circuit on elements of deliberate indifference)
Hill v. Lappin, 630 F.3d 468 (PLRA screening governed by Iqbal/Twombly standard)
Comstock v. McCrary, 273 F.3d 693 (discussion of subjective awareness element for deliberate indifference)