Echols v. Craig

Dist. Ct. erred in dismissing at screening stage under 28 USC section 1915A plaintiff-prisoner’s section 1983 action, alleging that defendant-prison dentist was deliberately indifferent to plaintiff’s medical needs when, while removing plaintiff's wisdom tooth, defendant sutured plaintiff’s gum with gauze while at least one half-inch piece of broken drill bit was still in plaintiff’s gum, and when said broken drill bit did not dislodge itself from plaintiff’s gum until 14 days after extraction of plaintiff’s wisdom tooth. While Dist. Ct. dismissed instant complaint based on its belief that allegations in complaint were “factually frivolous,” Ct. of Appeals found that plaintiff’s allegations were plausible, where: (1) defendant was individual performing dental services on plaintiff at time drill bit broke; and (2) there was ample reason to believe that defendant sutured extraction site without having located missing portion of broken drill bit. Moreover, instant complaint adequately alleged deliberate indifference where plaintiff alleged that defendant sutured his gum without accounting for all broken pieces of drill bit.