Patrick Davis v. Janet Pearson, 19-2403

Background:

After being stabbed, Davis received hospital treatment and was prescribed ongoing care: a neck collar, a sling, and a referral to a neurosurgeon for follow-up.
While incarcerated, Davis repeatedly requested the prescribed care; prison officials allegedly ignored, delayed, or denied those requests and documented grievances and appeals.
A Magistrate Judge screened Davis’s pro se complaint under the PLRA and recommended dismissal with leave to amend; Davis did not object because he never received the report and recommendation (R&R).
Seventeen months after the R&R, Davis notified the Clerk he had received no update; the District Court sua sponte dismissed his complaint with prejudice the next day without confirming whether Davis had received the R&R.
The Third Circuit held Davis’s complaint sufficiently alleged an Eighth Amendment deliberate-indifference claim (knowledge of a serious medical need and deliberate denial of prescribed care), vacated the dismissal, and remanded for further proceedings.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the complaint plausibly alleges Eighth Amendment deliberate indifference	Davis alleged specific prescribed treatments, repeated requests, documented denials, and officials’ knowledge	Magistrate argued allegations were conclusory legal statements insufficient under Iqbal	Court: Complaint pleaded sufficient factual allegations to state a deliberate-indifference claim and must be presumed true at this stage
Whether absence of a contractual right to higher pay (lost program pay) defeats damages or claim	Davis argued loss of program pay was a consequence of denied care and could be pleaded as damages	Magistrate viewed lost pay as non-contractual ‘‘carrot’’ and irrelevant to claim	Court: Lack of contractual right did not undermine the adequacy of the medical-care allegations and did not justify dismissal
Whether dismissal with prejudice was proper where plaintiff did not object to R&R because he never received it	Davis said he never received R&R and thus had no opportunity to object	Defendants relied on no-objection dismissal procedural rule	Court: Because record shows Davis did not receive R&R and wasn’t warned of forfeiture, de novo review applies and dismissal was improper
Whether the District Court erred by not allowing amendment after dismissal	Davis argued he should have an opportunity to amend if pleadings were deficient	District Court dismissed with prejudice and did not address amendment	Court: Did not reach amendment issue because initial complaint was adequately pleaded

Key Cases Cited

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (statement of pleading standard requiring plausible claim)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; disregard mere conclusory legal statements)
Garrett v. Wexford Health, 938 F.3d 69 (3d Cir. 2019) (courts must construe pro se inmate pleadings liberally)
Pearson v. Prison Health Serv., 850 F.3d 526 (3d Cir. 2017) (PLRA screening does not permit heightened skepticism of inmate claims)
Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (PLRA did not alter standards for permitting amendment of deficient pleadings)
Dooley v. Wetzel, 957 F.3d 366 (3d Cir. 2020) (deliberate-indifference claim elements at pleading stage)
Pension Benefit Guar. Corp. v. White Consol. Indus., Inc., 998 F.2d 1192 (3d Cir. 1993) (consideration of complaint and attached exhibits on motion to dismiss)
E.E.O.C. v. City of Long Branch, 866 F.3d 93 (3d Cir. 2017) (standard for plain-error review when no objection to R&R)
Leyva v. Williams, 504 F.3d 357 (3d Cir. 2007) (de novo review when pro se litigant wasn’t warned that failure to object would forfeit rights)