Mayfield v. Dental Department, 9:15-cv-00090

Plaintiff Larry M. Mayfield, a Texas prison inmate proceeding pro se and in forma pauperis, sued multiple prison medical/dental personnel and supervisors under 42 U.S.C. § 1983 alleging inadequate dental/medical care and contamination of food with human waste.
Defendants named include the Gib Lewis Unit Dental Department, Dental CDA Anna Stephens, Dentist Linda Garcia, Medical Practice Manager Kent Dickerson, Sergeant Supervisor Eric Lane, Administrative Segregation Security, and the TDCJ Office of Professional Standard/Health Service Division.
The case was referred to a magistrate judge who recommended dismissal for failure to state a claim and as frivolous.
Mayfield filed objections to the magistrate judge’s report; the district court reviewed the objections de novo under Fed. R. Civ. P. 72(b).
The court found the record showed Mayfield repeatedly received dental and medical evaluations and treatment at his request; his dissatisfaction with care amounted at most to negligence, not a constitutional violation.
The court also found no plausible supervisory liability: Mayfield conceded suing supervisors for failing to correct problems but alleged no personal involvement or causal link sufficient under § 1983.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of adequate dental/medical care states an Eighth Amendment claim	Mayfield alleges deliberate indifference to his dental/medical needs and contamination of food	Defendants assert Mayfield received evaluations/treatment; dissatisfaction is not deliberate indifference	Dismissed — mere dissatisfaction/possible negligence does not state an Eighth Amendment claim (no deliberate indifference)
Whether factual allegations support a claim against Sgt. Eric Lane for deliberate indifference	Lane failed to confirm Mayfield’s allegation that human waste fell in his food	Lane brought Mayfield for dental evaluation; no conduct showing deliberate indifference	Dismissed — actions described contradict deliberate indifference as to Lane
Whether supervisory defendants can be held liable under § 1983 on respondeat superior theory	Mayfield sues supervisors for refusing to correct the problem	Defendants contend supervisory liability requires personal involvement or causal link, not respondeat superior	Dismissed — supervisory liability not established; respondeat superior not available under § 1983
Whether the complaint is frivolous/subject to dismissal for failure to state a claim	Mayfield argues constitutional violations occurred	Defendants argue claims amount to negligence and lack factual/legal basis	Dismissed as frivolous/for failure to state a claim — Magistrate's recommendation adopted

Varnado v. Lynaugh, 920 F.2d 320 (5th Cir. 1991) (prisoner’s dissatisfaction with care does not alone establish Eighth Amendment violation)
Norton v. Dimazana, 122 F.3d 286 (5th Cir. 1997) (negligence or disagreement with treatment insufficient for § 1983 deliberate indifference claim)
Jackson v. Cain, 864 F.2d 1235 (5th Cir. 1989) (standards for evaluating Eighth Amendment claims concerning medical care)
Monell v. Dep’t of Social Servs., 436 U.S. 658 (1978) (municipal and supervisory liability under § 1983 requires personal involvement or policy-based causation)
Thompkins v. Belt, 828 F.2d 298 (5th Cir. 1987) (supervisory liability requires causal connection or personal participation in constitutional violation)