A prisoner's civil rights action against a psychiatrist (Weber Gallagher's client), who prescribed the prisoner two different antidepressant medications that allegedly "resulted in misconducts for sleeping during count," was dismissed last month by Chief Judge Christopher Conner, U.S. District Court for the Middle District of Pennsylvania, (Stafford v. Corizon Health, Inc.). When the prisoner complained to the psychiatrist, the prisoner reported he was allegedly advised to discontinue taking the antidepressants. After filing unsuccessful grievances with prison staff, the prisoner filed an action under 42 U.S.C. §1983 against the psychiatrist and prison staff for alleged violations of his Eighth Amendment and other civil rights
Chief Judge Conner observed in Stafford that "[t]he Eighth Amendment's proscription against cruel and unusual punishment requires that prison officials provide inmates with adequate medical care." A plaintiff establishes a prima facie Eighth Amendment medical claim where he can show "(i) a serious medical need, and (ii) acts or omissions by prison officials that indicate deliberate indifference to that need." A "serious medical need" was defined in Stafford as "one that has been diagnosed by a physician as requiring treatment or one that is so obvious that a lay person would easily recognize the necessity for a doctor's attention." Only where the prison official acts with "deliberate indifference" (a knowing disregard of an excessive risk to a prisoner's health or safety), does a prisoner st ate a viable claim. "A mere difference of opinion," Chief Judge Conner noted, "between the prison's medical staff and the inmate regarding the diagnosis or treatment...does not support a claim of cruel and unusual punishment."
In Stafford, Chief Judge Conner concluded that even if the prisoner's mental health disorder represented a serious medical need, the prisoner's allegations demonstrated the psychiatrist was not deliberately indifferent to that need. The Judge observed that the psychiatrist interacted with the prisoner on at least one occasion and noted the prisoner reported the psychiatrist had allegedly advised him to stop taking the medications after the prisoner had allegedly complained of over-sleeping. Instead of alleging the psychiatrist's prescription resulted in any risk of harm to his health, the prisoner alleged he "continued to suffer from sleeping during count" and "was unable to adjust his sleeping habit." Chief Judge Conn er held that because the prisoner's claims against the psychiatrist amounted to "nothing more than his subjective disagreement with the treatment decisions and medical judgment of the medical staff at the prison," the prisoner did not state a claim for violation of his civil rights.
Comment: Stafford reaffirms the standards prisoners face in bringing civil rights actions against prison officials who render medical care to them. Courts will not second-guess prison officials' diagnoses and prescribed treatments, and only upon a showing of deliberate indifference to a serious medical need can a prisoner state a claim of relief. Under Stafford, not being able to adjust one's sleeping habit after taking antidepressants does not constitute a serious medical need and a prisoner's disagreement with a prescription or treatment plan does not state a claim for relief.