Lynch v. Thomson
1:23-cv-01167
| M.D. Penn. | Aug 6, 2025Background
- Michael D. Lynch, a federal inmate, brought a civil rights suit under Bivens against Dr. Eryn Siddall, a psychologist at LSCI-Allenwood.
- Lynch alleged that Siddall provided an inadequate mental health evaluation during disciplinary proceedings, failing to diagnose his anxiety and depression, thus constituting deliberate indifference to a serious medical need.
- Lynch initially brought claims against multiple defendants; all but the claim against Siddall for deliberate indifference were previously dismissed with prejudice.
- Siddall moved to dismiss or for summary judgment; Lynch filed motions to reinstate an FTCA claim and for a temporary restraining order, but failed to support them as required by local rules.
- The court deemed Lynch's unsupported motions withdrawn and proceeded to address only the Bivens deliberate indifference claim against Siddall.
- The court found Lynch's claim presented a new Bivens context and was barred due to special factors, and alternatively failed to state a claim for deliberate indifference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Bivens claim for mental health deliberate indifference | Siddall failed to diagnose/treat his anxiety and depression, which was deliberate indifference to serious medical need | Claim presents new Bivens context and is barred by special factors; BOP has administrative remedy | Claim is a new Bivens context; special factors bar extension; dismissed |
| Sufficiency of deliberate indifference claim | Siddall’s failure to diagnose mental illness constituted deliberate indifference | Plaintiff merely disagrees with clinical assessment, not a true denial of care | No adequate claim stated; mere disagreement with diagnosis is insufficient |
| Motion to reinstate FTCA claims | Original complaint should be construed to raise FTCA tort claims | FTCA was not pled or indicated—no FTCA claim exists | Motion deemed withdrawn and would fail |
| Motion for temporary restraining order | Needs injunctive relief to litigate case against officials at new prison | Motion is unsupported, targets non-party actors | Motion deemed withdrawn and would fail |
Key Cases Cited
- Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) (establishes implied damages remedy for certain constitutional violations by federal officials)
- Ziglar v. Abbasi, 582 U.S. 120 (2017) (significantly narrows contexts where Bivens can be extended)
- Carlson v. Green, 446 U.S. 14 (1980) (recognized Bivens remedy for Eighth Amendment violations for inadequate physical medical care)
- Farmer v. Brennan, 511 U.S. 825 (1994) (explained deliberate indifference standard for Eighth Amendment claims)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets standard for plausibility in pleadings under Rule 12(b)(6))