Lewis v. Wade, 1:16-cv-00835

Background

John Thomas Lewis, a Virginia inmate, sued under 42 U.S.C. § 1983 alleging Eighth Amendment deliberate indifference after he fell from a top bunk at Henrico County Jail on July 9, 2014 and reinjured his arm.
Lewis had previously received intermittent medical treatment for elbow and back complaints and had a prior ‘‘bottom bunk’’/cot accommodation at times; medical records show normal range of motion and no disabling deficits before the fall.
On July 8, 2014 Lewis asked Lt. Robinson to move to a less crowded cell; Robinson verbally approved the move pending classification recording, but Deputy Amoah later ordered Lewis back to his assigned cell during a count.
The top bunk in Lewis’s assigned cell lacked ladder/rails; the inmate originally assigned to the top bunk had moved to the cot, leaving Lewis without his cot when ordered to return to the top bunk.
Lewis fell while attempting to use the top bunk, was taken to the hospital, and later received a ‘‘no top bunk’’ restriction; he alleged defendants ignored his medical needs and refused time to produce documentation of his bottom-bunk restriction.
Defendants moved for summary judgment; the court concluded that, even if defendants were indifferent, Lewis failed to show an objectively serious medical need sufficient to sustain an Eighth Amendment claim and granted summary judgment for defendants.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lewis had an objectively serious medical need supporting an Eighth Amendment claim	Lewis argued his prior bottom-bunk accommodation and ongoing elbow/back/nerve complaints made climbing a top bunk dangerous and constituted a serious medical need	Defendants argued medical records show intermittent, non-debilitating complaints, normal strength and range of motion, and no clinical evidence of a condition posing substantial risk of serious harm	Court held Lewis failed to show a sufficiently serious medical condition as required for an Eighth Amendment claim
Whether defendants acted with deliberate indifference to a serious medical need	Lewis asserted deputies ignored his request to retrieve documentation and forced him toward the top bunk despite his condition	Defendants maintained they followed policy (only Classification can change assignments), denied knowledge of a serious medical risk, and that Lewis was not visibly incapacitated	Court assumed without deciding that defendants acted with indifference but ruled claim fails on objective-seriousness element
Whether non-Classification officers could lawfully change cell assignments in an emergency	Lewis argued officers could move inmates when necessary and thus should have accommodated him	Defendants asserted only Classification staff have authority to assign cells; non-Classification deputies may place noncompliant inmates in holding	Court relied on policy evidence that Classification controls assignments and found no material fact creating constitutional liability on this ground
Whether summary judgment was appropriate on qualified immunity grounds (alternative)	N/A (Lewis sought to hold officers liable)	Defendants argued qualified immunity in the alternative	Court did not reach qualified immunity because it resolved the case on the merits (no objectively serious need)

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference framework)
Farmer v. Brennan, 511 U.S. 825 (subjective deliberate indifference standard)
Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard)
Celotex Corp. v. Catrett, 477 U.S. 317 (movant burden on summary judgment)
Jackson v. Lightsey, 775 F.3d 170 (objective-seriousness inquiry for medical need)