Marvin Mead v. Charles Palmer
2015 U.S. App. LEXIS 12792
| 8th Cir. | 2015Background
- Mead, civilly committed at CCUSO, sues under §1983 claiming denial of partial dentures and deliberate indifference to a serious medical need.
- Defendants moved for summary judgment arguing Mead had funds to pay for a partial denture and that no serious medical need existed.
- Undisputed facts: Mead had regular dental care, weight gain, could still eat, and did not request a soft diet or loss weight, indicating no demonstrated serious medical need.
- Dr. DeStigter testified that weight loss signals serious need for dentures, but Mead’s records did not note such a need; nursing records show Mead requested dentures, but the response was that dentures are not paid for.
- Policy and financial-status evidence: Mead had about $1,300; alleged denture cost around $1,200; CCUSO policy shift to require “demonstration of financial responsibility” rather than a fixed savings amount.
- The district court denied summary judgment, finding genuine issues on serious medical need and deliberate indifference; the court also found Dr. Smith and Benson could be liable in their individual capacities.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mead had a serious medical need for dentures | Mead argues his chewing impairment and gum injuries show serious need. | Mead did not show a medical necessity for dentures; weight gain and calories negate need. | No serious medical need established. |
| Whether the defendants were deliberately indifferent | Mead asserts denial of dentures without accommodation showed indifference. | No evidence of knowledge of a serious need and disregard; policy not clearly requiring dentures. | No deliberate indifference proven. |
| Whether the right was clearly established at the time | Curtiss-like precedent supports entitlement to dentures for a disabled patient. | No clearly established right given the facts; Curtiss controls. | Right not clearly established; qualified immunity applies. |
Key Cases Cited
- Stoner v. Watlingten, 735 F.3d 799 (8th Cir. 2013) (de novo review of qualified-immunity disposition; court may review only legal issues surrounding immunity)
- Robbins v. Becker, 715 F.3d 691 (8th Cir. 2013) (limits appellate review to denial of immunity to extent it turns on law)
- Keil v. Triveline, 661 F.3d 981 (8th Cir. 2011) (two-prong qualified-immunity analysis; flexibility in ordering prongs)
- Pearson v. Callahan, 555 U.S. 223 (2009) (establishes two-prong framework for qualified immunity)
- Curtiss v. Benson, 583 Fed.Appx. 598 (8th Cir. 2014) (denial of dentures not clearly establishing deliberate indifference; similar CCUSO context)
- Tolan v. Cotton, 134 S. Ct. 1861 (2014) (clarifies fair-warning inquiry for clearly established law)
- Curtiss v. Benson, 583 Fed.Appx. 598 (8th Cir. 2014) (recounted as controlling example for this case)
- Stoner v. Watlington, 735 F.3d 799 (8th Cir. 2013) (cites de novo review of qualified-immunity decision)