30. Mental problems (prisoner).

U.S. Appeals Court ADEQUACY OF CARE

Hallett v. Morgan, 287 F.3d 1193 (9th Cir. 2002). In a class action, female prisoners at a stat prison secured a consent decree that addressed health care concerns. The prisoners challenged the prison's attempt to end the decree, sought additional time for court involvement and moved to have prison officials held in contempt for past violations of the decree. The district court denied the prisoners' motions and granted the prison officials' motion to terminate the consent decree. The prisoners appealed and the appeals court affirmed in part, reversed in part and remanded. The appeals court held that dental care and mental health care did not violate the Eighth Amendment, but ordered the district court to consider retrospective relief on remand. The court noted that the district court should have considered whether officials were in contempt for failing to comply with other medical care provisions of the consent decree. (Washington Corrections Center for Women)

U.S. District Court SUICIDE FAILURE TO PROVIDE CARE

Pelletier v. Magnuson, 201 F.Supp.2d 148 (D. Me. 2002). A personal representative for the estate of an inmate who committed suicide in a state prison filed a [section] 1983 complaint in state courts, alleging Eighth Amendment violations. The district court granted summary judgment for all of the medical defendants, finding that the alleged missing or tampered documents relating to the deceased inmate's medical treatment did not establish that employees of the prison's contracted health care provider were deliberately indifferent to his serious medical needs. The court held that a social worker, medical doctor, and regional supervisor of medical services were not deliberately indifferent. The court found that a licensed psychiatrist was not administratively negligent for allegedly not knowing that the inmate was psychotic and suicidal at all times. The court noted that the decision to scale down the inmate's care was made by a treatment team and was not the result of financial considerations. (Maine State Prison)

U.S. District Court MEDICAL CARE CONDITIONS

Carlyle v. Aubrey, 189 F.Supp.2d 660 (W.D.Ky. 2001). A former prisoner brought a [section] 1983 action against a county jail alleging Eighth Amendment violations. The district court granted summary judgment in favor of the defendants. The court held that the prisoner's medical needs were not treated with deliberate indifference, noting that medication was administered twice during the prisoner's one-day stay at the jail, he was intoxicated when arrested, and he admitted that his seizures caused memory loss. The court held that the prisoner was not subjected to unconstitutional conditions of confinement, even though water service in his cell was broken, he was forced to sleep on the floor, and he was fed only a bologna sandwich. The prisoner had admitted that he was offered drinking water on at least two occasions and that officers brought in water to flush the toilet. The court noted that although forcing a prisoner to sleep on the floor for extended periods may amount to an Eighth Amendment violation, the temporary inconvenience of one night spent on the floor does not. (Jefferson County Jail, Kentucky)