James Saylor v. Randy Kohl, M.D.
2016 U.S. App. LEXIS 1459
8th Cir.2016Background
- Saylor, a Nebraska inmate, alleges Eighth, First, and Fourteenth Amendment violations related to his PTSD treatment.
- Dr. Christensen treated Saylor for PTSD at NSP until 2005; subsequent care involved Drs. Kamal, Baker, Baker at TSCI and other NDCS staff.
- Saylor was transferred to Tecumseh State Correctional Institution (TSCI) in 2010 for psychiatric care and placed in intensive segregation/SMU due to safety and housing concerns.
- A state court tort judgment in 2010 found staff negligent in protecting Saylor and in providing medical care between 2002–2005, with $250,000 awarded.
- The district court dismissed some defendants and denied qualified immunity for others; on appeal, the Eighth Circuit reversed, addressing Eighth, First, and Fourteenth Amendment claims and the qualified-immunity issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eighth Amendment: deliberate indifference to PTSD treatment | Saylor asserts defendants knew of serious medical needs and ignored them after Christensen left NSP. | Defendants contend they provided medical care and did not act with deliberate indifference. | No Eighth Amendment violation; defendants entitled to qualified immunity. |
| First Amendment retaliation | Transfer to TSCI and treatment changes were retaliatory for filing the state tort suit. | Transfers and treatment changes were non-retaliatory and based on medical judgment. | No retaliation; no First Amendment violation; qualified immunity applies. |
| Fourteenth Amendment due process—transfer and SMU confinement | Transfer and segregation imposed atypical, significant hardship beyond ordinary prison life. | Transfer to obtain psychiatric care and SMU confinement were permissible accommodations. | No due process violation; action within legitimate state interests; qualified immunity. |
Key Cases Cited
- Nelson v. Corr. Med. Servs., 583 F.3d 522 (8th Cir. 2009) (deliberate indifference standard for medical care in prison)
- Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (deliberate indifference framework for prison conditions)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (requires actual knowledge of a serious medical need and disregard)
- Anderson v. Creighton, 483 U.S. 635 (U.S. 1987) (objective contours of clearly established rights)
- Buckley v. Rogerson, 133 F.3d 1125 (8th Cir. 1998) (right must be clearly established to defeat immunity)
- Meachum v. Fano, 427 U.S. 215 (U.S. 1976) (transfer within prison system does not violate due process)
- Sandin v. Connor, 515 U.S. 472 (U.S. 1995) (typicality of confinement impact for due process)
- Meuir v. Greene Cty. Jail Emps., 487 F.3d 1115 (8th Cir. 2007) (prison inmates have no right to a particular course of treatment)
- Goff v. Burton, 7 F.3d 734 (8th Cir. 1993) (no liberty interest in institutional placement absent due process)