Henderson v. Scott
4:23-cv-05280
D.S.C.May 19, 2025Background
- Aryee Henderson, an inmate at Lee Correctional Institution, sued Nurse Gregory Scott for alleged deliberate indifference to a serious medical need after Henderson claimed he ingested a handful of pills and reported feeling suicidal/homicidal on April 8, 2023.
- Nurse Scott was employed as a licensed practical nurse by ShareStaff, LLC, a contractor for the South Carolina Department of Corrections.
- Henderson alleged that Scott failed to respond appropriately and did not seek additional medical care or report the incident, leading to further physical symptoms.
- Scott stated in his affidavit that he reported the incident immediately to both the correctional officer on duty and the charge nurse.
- Henderson sought monetary and injunctive relief, including transfer to a different facility and regular mental health assessments.
- The magistrate judge recommended granting summary judgment in favor of Scott; Henderson objected, but the district court ultimately adopted the magistrate judge’s report in full, entering judgment for Scott.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deliberate indifference under Eighth Amendment | Scott failed to respond or report the overdose after Henderson disclosed suicidal intent and pill consumption | Scott notified the officer and charge nurse immediately after the incident | No deliberate indifference; at most, possible negligence, which is insufficient under Eighth Amendment standards |
| Sufficiency of evidence at summary judgment | Scott’s affidavit was uncorroborated, and Henderson assumed Scott notified no one | Sworn affidavit under penalty of perjury is sufficient, especially where Henderson admitted an officer responded shortly after | Scott’s affidavit is sufficient; no genuine dispute of material fact |
| Denial of further discovery | Lack of legal resources and denied opportunity for more discovery hindered Henderson’s case | Discovery was open until deadline, and extension was denied for lack of diligence | No abuse of discretion; discovery procedures were proper |
| Scope of injunctive relief sought | Requested transfers and medical assignments as injunctive relief | Scott lacked authority to grant requested injunctive relief (not a policymaker) | Relief denied; Scott cannot provide the relief sought |
Key Cases Cited
- Estelle v. Gamble, 429 U.S. 97 (1976) (establishes the standard for deliberate indifference to inmates’ serious medical needs under the Eighth Amendment)
- Farmer v. Brennan, 511 U.S. 825 (1994) (defines deliberate indifference standard, requiring subjective recklessness)
- Young v. City of Mount Ranier, 238 F.3d 567 (4th Cir. 2001) (discusses the high standard required to show deliberate indifference)
- Iko v. Shreve, 535 F.3d 225 (4th Cir. 2008) (details requirements for Eighth Amendment medical claims)
- Heyer v. United States Bureau of Prisons, 849 F.3d 202 (4th Cir. 2017) (clarifies what constitutes a serious medical need for Eighth Amendment claims)