When a prison official fails to provide necessary medical care to an inmate, legal action may be pursued against the individual. However, claiming deliberate indifference to an inmate’s serious medical needs requires meeting specific criteria. As exemplified by the case below, these factors are crucial in preventing individuals from bringing frivolous claims against government officials, ensuring that legitimate cases receive the attention they deserve.
In this case, Gregory Bailey, a Louisiana prisoner, filed a lawsuit against several defendants, including East Baton Rouge Parish Prison, the prison warden, the 19th Judicial District Court for East Baton Rouge Parish, a judge, and Dr. Vincent Leggio, alleging acts of deliberate indifference to his serious medical needs. The U.S. District Court for the Middle District of Louisiana dismissed Bailey’s claims, stating a failure to state a claim upon which relief can be granted under Federal Rule of Civil Procedure 12(b)(6) and summary judgment under Federal Rule of Civil Procedure 56(a). This appeal to the U.S. Fifth Circuit Court of Appeal follows.
In his appeal, Bailey moved to progress in forma pauperis, thereby challenging the District Court’s decision that his appeal was not accepted in good faith. The Court of Appeal then reviewed Bailey’s good faith claims regarding whether his legal points were substantiated on their merits and not frivolous. See Howard v. King.
On appeal, Bailey claimed the District Court erred in dismissing his claims that Dr. Leggio was purposefully indifferent to his medical needs. Bailey did not fight the dismissal of his assertions against the prison, the prison warden, the 19th Judicial District Court, or the judge by the District Court.
To win a claim for deliberate indifference, the claimant must show that a government official’s intentional indifference posed a significant risk of grave medical harm. See Wagner v. Bay City. It can be shown that an official acted intentionally indifferent to a prison inmate’s health if the official 1) knew the inmate was facing a significant risk of serious injury and 2) failed to take reasonable actions to decrease the risk of injury. See Farmer v. Brennan.
The Court of Appeals found Bailey’s argument amounted to disagreement with treatment type or a claim of malpractice, not deliberate indifference. Additionally, the Court of Appeal found the evidence provided by Dr. Leggio established there was no real issue of material fact, Dr. Leggio did not disregard Bailey’s complaints or refuse to treat him, did not purposefully treat him wrongly, and did not show a wanton indifference for his serious health concerns. The Court of Appeal found that Dr. Leggio’s presented evidence contradicted Bailey’s claims that Dr. Leggio was intentionally indifferent, purposely failed to help Bailey, and allowed Bailey to suffer. As such, Bailey did not present viable evidence to show a real triable issue.
As Bailey failed to establish a genuine issue for trial regarding his deliberate indifference claim against Dr. Leggio, the Court of Appeal denied his motion in forma pauperis and dismissed his appeal as frivolous.
This case highlights the significance of presenting essential evidence when alleging deliberate indifference against prison officials. It underscores the importance of seeking the guidance of experienced attorneys knowledgeable in various claims to ensure the necessary evidence is provided to support arguments effectively. By understanding the requirements and adhering to the standards set by the court, inmates can pursue legitimate claims and hold responsible parties accountable for their actions or inactions.
Written by Berniard Law Firm Blog Writer: Samantha Calhoun
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