Spavone v. New York State Department of Correctional Services
719 F.3d 127
| 2d Cir. | 2013Background
- Spavone, an inmate with PTSD, sought a medical leave of absence (MLOA) from DOCS in 2008 to obtain community-based residential/inpatient PTSD treatment; he claimed in-prison treatment was insufficient.
- DOCS/OMH framework: OMH provides mental-health services under an MOU with DOCS; some in-prison facilities offer outpatient, intermediate, or inpatient-level care; DOCS regulations allow MLOAs only for medical/dental treatment "absolutely necessary" and not available in the facility.
- Spavone submitted supporting letters from prison mental-health clinicians; OMH staff acknowledged community treatment could be beneficial but indicated Woodbourne’s treatment had been effective and CNYPC inpatient care was not indicated.
- Woodbourne’s temporary release committee denied Spavone’s application based on his criminal history; Joy (DOCS Director of Temporary Release) later denied the appeal, stating rules do not provide MLOAs for mental-health reasons because OMH services were available in facilities.
- Spavone sued under 42 U.S.C. § 1983 alleging Equal Protection and Eighth Amendment violations; the district court denied qualified-immunity summary judgment, finding genuine issues of fact. The Second Circuit reversed, holding the individual defendants entitled to qualified immunity and directing dismissal of the § 1983 claims against them.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendants violated Equal Protection by denying MLOAs for mental-health treatment while allowing MLOAs for other "absolutely necessary" medical care | Spavone: DOCS carved out mental-health care from §851(6) protections, resulting in discriminatory denial of necessary treatment | Fischer/Joy: It was reasonably conceivable that necessary mental-health care was available in prisons under the OMH–DOCS MOU, so distinguishing mental vs. physical medical leave was rational | Defendants entitled to qualified immunity because a reasonable official could have believed the MLOA policy (as applied) had a rational basis |
| Whether defendants acted with deliberate indifference in violation of the Eighth Amendment by denying the leave request | Spavone: Denial risked serious harm by blocking access to required treatment outside prison | Defendants: No evidence they actually knew denial posed a substantial, obvious risk of serious harm; treatment appeared available in prison | No genuine issue of subjective deliberate indifference; qualified immunity applies |
| Whether Nick Chalk had personal involvement sufficient for §1983 liability | Spavone: Committee chair’s denial contributed to the alleged policy-based violation | Chalk: He denied for criminal-history reasons and had no role in any alleged categorical policy excluding mental-health MLOAs | Chalk not personally involved in the policy decision; entitled to qualified immunity |
| Whether the denial is reviewable on interlocutory appeal (qualified immunity) | Spavone: district court’s factual findings should stand | Defendants: Qualified immunity denial is appealable to the extent legal questions are presented; court may decide immunity where reasonable officials could believe conduct lawful | Court reviewed legal aspects under collateral order doctrine, accepted district court’s factual findings, and resolved immunity as a question of law in defendants’ favor |
Key Cases Cited
- Mitchell v. Forsyth, 472 U.S. 511 (U.S. 1985) (qualified immunity denial is appealable as collateral order)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (qualified immunity analysis standards; objective reasonableness)
- Estelle v. Gamble, 429 U.S. 97 (U.S. 1976) (Eighth Amendment deliberate indifference to serious medical needs)
- Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (subjective awareness standard for Eighth Amendment claims)
- Crawford-El v. Britton, 523 U.S. 574 (U.S. 1998) (qualified immunity protects officials from burdens of discovery/trial)
- Bolmer v. Oliveira, 594 F.3d 134 (2d Cir. 2010) (limits on appellate review of interlocutory denials of qualified immunity)
- Salim v. Proulx, 93 F.3d 86 (2d Cir. 1996) (appellate review of qualified immunity limited to facts favorable to plaintiff)
- Turner v. Safley, 482 U.S. 78 (U.S. 1987) (prison regulation review standard; distinguished as inapplicable here)
- Salahuddin v. Goord, 467 F.3d 263 (2d Cir. 2006) (two-part deliberate indifference test: objective seriousness and subjective recklessness)