Smith 619752 v. Davids, 1:19-cv-00402

Background

Plaintiff Ashton Smith, an MDOC prisoner with a history of corneal transplants, alleges he developed a right-eye staph infection/corneal ulcer between August 11–15, 2018 and repeatedly asked two medication-line nurses (R.N. Corinne Spear and R.N. James Leland) for help.
Smith says the nurses refused treatment and made retaliatory remarks because he previously insulted another nurse (LPN Page).
The nurses state they worked the I-unit medication line (limited to medication distribution), did not perform clinical assessments there, did not work on August 14 (the date of Smith's worst alleged condition), and deny making the alleged comments.
Medical records show Smith could request clinic care by a Health Care Request form or kite, that he submitted kites previously, and that on August 15 staff arranged urgent off-site treatment at Kellogg Eye Center (which Smith initially refused but then accepted).
After off-site treatment Smith was diagnosed with corneal ulceration and received antibiotics; he also told staff he would not consistently use prescribed eye drops.
The magistrate judge recommended granting summary judgment for defendants on the Eighth Amendment claim and declining supplemental jurisdiction over state-law malpractice/gross-negligence claims, dismissing them under 28 U.S.C. § 1367(c)(3).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether nurses were deliberately indifferent to a serious medical need in violation of the Eighth Amendment	Smith: nurses saw his worsening eye, knew his transplant history, refused treatment or referral, and delayed care causing ulcer and vision loss	Spear/Leland: worked only medication line (not clinical exams), lacked access to records, did not provide clinical treatment, Smith knew procedure to seek care and sometimes refused meds/appointments	Court: No deliberate indifference; summary judgment for defendants (no subjective culpability)
Whether to retain state-law claims for gross negligence/medical malpractice after dismissal of federal claims	Smith: pursues malpractice/gross negligence tied to same facts	Defendants: federal claims disposed; supplemental jurisdiction discretionary	Court: declined supplemental jurisdiction and dismissed state-law claims under § 1367(c)(3)

Key Cases Cited

Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (Eighth Amendment deliberate indifference to serious medical needs actionable under § 1983)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (deliberate indifference requires actual subjective knowledge of substantial risk)
Hudson v. McMillian, 503 U.S. 1 (U.S. 1992) (objective component: serious medical need or harm)
Wilson v. Seiter, 501 U.S. 294 (U.S. 1991) (subjective component requires sufficiently culpable state of mind)
Whitley v. Albers, 475 U.S. 312 (U.S. 1986) (distinguishing obduracy/wantonness from inadvertence)
Scott v. Harris, 550 U.S. 372 (U.S. 2007) (courts need not adopt versions of facts blatantly contradicted by the record)
Copeland v. Machulis, 57 F.3d 476 (6th Cir. 1995) (summary judgment burdens explained)
Santiago v. Ringle, 734 F.3d 585 (6th Cir. 2013) (deliberate indifference standard as criminal-recklessness analog)
Pinkston v. Madry, 440 F.3d 879 (7th Cir. 2006) (inmate-caused delay in seeking treatment can defeat deliberate-indifference claim)
Harlow v. Fitzgerald, 457 U.S. 800 (U.S. 1982) (qualified immunity shields officials unless they violate clearly established rights)
Musson Theatrical, Inc. v. Federal Express Corp., 89 F.3d 1244 (6th Cir. 1996) (general rule to dismiss state claims when federal claims are dismissed before trial)
Campanella v. Commerce Exchange Bank, 137 F.3d 885 (6th Cir. 1998) (discussing supplemental jurisdiction after dismissal of federal claims)
McLean v. 988011 Ontario Ltd., 224 F.3d 797 (6th Cir. 2000) (summary-judgment standards for viewing evidence in nonmovant's favor)
Palmer v. Wagner, [citation="3 F. App'x 329"] (6th Cir. 2001) (voluntary refusal of treatment can preclude Eighth Amendment claim)