Roach v. Hiland
5:12-cv-00169
W.D. Ky.Sep 23, 2014Background
- Plaintiff Antoine Roach, a KSP inmate, sued physician Steve Hiland and APRN Chanin Hiland alleging denial of medical care (Eighth Amendment) and state-law malpractice; claims against certain parties previously dismissed but Eighth Amendment claims proceed against these defendants in their individual capacities for damages and official capacities for injunctive relief.
- Roach filed a second motion for summary judgment asserting unclean hands, alleging defendants committed perjury in interrogatory answers, attaching his medical records and case lists.
- Defendants opposed and also moved for a new deadline for dispositive motions, stating they left DOC employment and may seek private counsel and lack convenient access to medical records.
- Roach filed a motion to strike (challenging defendants’ filings); defendants responded.
- The court evaluated Roach’s summary-judgment motion under Rule 56 standards, construing all inferences against the moving party.
- The court denied Roach’s summary judgment and motion to strike, granted defendants a final extension to October 31, 2014 to file dispositive motions, and noted no dispositive motions were filed within the prior 60 days and medical records are available to counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Roach is entitled to summary judgment on his medical-care claims | Roach contends defendants lied in interrogatory answers and that the record (medical charts) plus cited cases establish liability; invokes unclean hands | Defendants dispute plaintiff's factual assertions and rely on need for further development; defended against summary judgment | Denied — plaintiff failed to show no genuine dispute of material fact; court draws inferences for defendants |
| Whether plaintiff's submissions (interrogatory responses, records) suffice to overcome summary judgment standard | Roach asserts his evidence proves claims and impeaches defendants | Defendants argue factual disputes remain and evidence is insufficient for judgment as a matter of law | Denied — mere submissions and allegations insufficient; plaintiff must present evidence enabling a reasonable trier of fact to find for him |
| Whether plaintiff's Motion to Strike should be granted | Roach sought to strike defendants’ filings as improper or untimely | Defendants opposed; court considered the timing and substance and found no basis to strike | Denied — court rejected strike request |
| Whether defendants should receive an extension to file dispositive motions | N/A | Defendants requested extension to seek private counsel and access records | Granted — final extension to October 31, 2014; noted prior 60 days passed without filings and records are available |
Key Cases Cited
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (U.S. 1986) (summary-judgment standard and drawing inferences against moving party)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (plaintiff must present evidence on which a reasonable jury could find for plaintiff)
- Street v. J. C. Bradford & Co., 886 F.2d 1472 (6th Cir. 1989) (not every factual dispute defeats summary judgment)
- Hartsel v. Keys, 87 F.3d 795 (6th Cir. 1996) (plaintiff must present a jury question as to each element)
- Moinette v. Elec. Data Sys. Corp., 90 F.3d 1173 (6th Cir. 1996) (mere speculation cannot defeat a properly supported summary-judgment motion)
