William Mitchell v. Warden
2017 U.S. App. LEXIS 20211
| 11th Cir. | 2017Background
- Mitchell filed a February 2016 pro se 42 U.S.C. §1983 suit against Autry State Prison officials for deliberate indifference to hepatitis C treatment.
- He alleged lack of treatment caused cirrhosis and that Harvoni was not provided.
- The District Court dismissed under 28 U.S.C. §1915(g) (the three-strikes rule) and, alternatively, sanctioned him under Rule 11 for a false disclosure of prior lawsuits.
- Mitchell died of liver cancer on July 15, 2017; his son William Mitchell substituted as plaintiff-appellant.
- On appeal, the panel reviews de novo the §1915(g) three-strikes issue and reviews Rule 11 sanctions for abuse of discretion; the merits of the deliberate-indifference claim are considered if viable.
- This court reverses both district-court bases for dismissal and evaluates whether the complaint states a deliberate-indifference claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Mitchell's allegations show imminent danger under §1915(g)? | Mitchell alleges total lack of hepatitis C treatment causing cirrhosis, aligning with Brown's imminent danger framework. | Prison allegedly no complete denial of treatment; focus on not receiving Harvoni only. | Yes; allegations constitute imminent danger, satisfying the §1915(g) exception. |
| Was the sanction for false disclosure proper under Rule 11? | Sanction procedurally flawed; due process required notice and opportunity to respond. | Sanction appropriate for knowingly false filing. | No; district court erred by imposing sanctions without notice or response opportunity. |
| Does the complaint state a deliberate-indifference claim? | Hepatitis C diagnosed; officials knew and withheld treatment, causing deterioration. | Allegations describe requesting newer treatment rather than a total withdrawal. | Yes; allegations amount to a deliberate-indifference claim. |
Key Cases Cited
- Brown v. Johnson, 387 F.3d 1344 (11th Cir. 2004) (imminent danger exists where treatment is withdrawn for serious diseases)
- Dupree v. Palmer, 284 F.3d 1234 (11th Cir. 2002) (three-strikes dismissal should be without prejudice under §1915(g))
- Attwood v. Singletary, 105 F.3d 610 (11th Cir. 1997) (Rule 11 sanctions require notice and opportunity to respond)
- Donaldson v. Clark, 819 F.2d 1551 (11th Cir. 1987) (due process requires notice before Rule 11 sanctions)
- Koon v. United States, 518 U.S. 81 (1996) (district court abuses discretion when it errs as a matter of law)
- Brown v. Johnson, not applicable (same Brown cited above) (11th Cir. 2004) (see Brown for definition of imminent danger under §1915(g))