John Williams v. Randy Watson, 891 F.3d 701

Background

John Henry Williams, an ADC inmate housed at Varner Super Max, experienced severe dental pain beginning June 2013 and submitted sick-call requests; nurses recommended dental treatment but Varner lacked an onsite dentist.
Dr. Russell from Cummins Unit treated Varner inmates intermittently; Williams waited ~3 months for dental care, during which his condition worsened, he self-extracted two teeth, and Dr. Russell later extracted seven more teeth.
Williams alleges he repeatedly notified four Varner officials (Warden Watson, Asst. Warden Jackson, Maj. Malone, Maj. Bolden) of his pain and begged for help; he claims each knew of his condition and took no steps to secure dental treatment.
Defendants moved for summary judgment asserting qualified immunity, arguing they were non-medical staff and Corizon (a contractor) was responsible for dental care; the district court denied qualified immunity, finding a triable issue whether defendants were deliberately indifferent.
After this court decided Cullor v. Baldwin (addressing liability for dentist shortages), Defendants sought reconsideration based on Cullor; the district court denied reconsideration, and the defendants appealed that denial under Rule 60(b).
The Eighth Circuit affirmed, holding the case is distinguishable from Cullor because Williams alleges personal knowledge and inaction by custodial officials rather than a general staffing-shortage claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Varner officials are liable under § 1983 for deliberate indifference to serious dental needs	Williams: each official knew of his severe dental pain and failed to act to obtain dental care	Defendants: non-medical custodial staff; Corizon contract meant they were not responsible; qualified immunity applies	Court: triable issue exists; officials may be liable if they personally knew and failed to act
Whether Cullor requires qualified immunity here	Williams: Cullor is distinguishable; this is personal-knowledge/inaction case, not staffing policy	Defendants: Cullor shows officials addressing staffing shortages are immune; it was intervening law supporting reconsideration	Court: Cullor is distinguishable; denial of reconsideration not an abuse of discretion
Whether contracting medical services to Corizon absolves custodial officials of constitutional duty	Williams: contracting does not relieve custodial duty to ensure inmates receive care	Defendants: Corizon was responsible for dental care under contract	Held: Contracting does not immunize custodial officials from liability if they fail to ensure treatment
Appellate jurisdiction over denial of summary judgment after Rule 60(b) motion	Defendants: seek review of original denial based on intervening case	Williams: appeal from denial of reconsideration does not resurrect untimely appeal of original order	Court: Only has jurisdiction to review denial of Rule 60(b) motion; original denial not timely appealed

Key Cases Cited

Cullor v. Baldwin, 830 F.3d 830 (8th Cir. 2016) (officials who actively addressed dentist shortage entitled to qualified immunity)
Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to serious medical needs violates Eighth Amendment)
Langford v. Norris, 614 F.3d 445 (8th Cir. 2010) (prison officials must ensure inmates receive needed medical treatment)
Crooks v. Nix, 872 F.2d 800 (8th Cir. 1989) (contracting with private provider does not relieve state of constitutional duties)
Boyd v. Knox, 47 F.3d 966 (8th Cir. 1995) (delay in dental care with knowledge of suffering can support Eighth Amendment claim)
Fields v. Gander, 734 F.2d 1313 (8th Cir. 1984) (failure to provide dental care despite known severe pain may constitute deliberate indifference)
West v. Atkins, 487 U.S. 42 (1988) (state's contracting for medical care does not eliminate constitutional duties)
Farmer v. Brennan, 511 U.S. 825 (1994) (officials who know of a substantial risk may avoid liability if they respond reasonably)