Leiser v. Kloth

Dist. Ct. erred in denying defendants-prison officials’ motion for summary judgment in plaintiff-prisoner’s section 1983 action alleging that defendants were deliberately indifferent to his serious medical needs, where: (1) plaintiff informed defendants that he had Post Traumatic Stress Disorder that required that they not stand directly behind him, because doing so triggered his mental health symptoms; and (2) defendants thereafter stood behind him on increased occasions while patrolling commons areas. Defendants were entitled to qualified immunity because plaintiff failed to show that at time of defendants’ actions there was clear constitutional right to have accommodation of inmate-reported mental diagnosis without confirmation from medical staff or existence of treatment plan. Ct. emphasized that it is essential that non-medical correctional staff comply with orders from medical staff, and instant record reflected that there were no such orders. Result might be different if medical staff had ordered correctional staff to provide accommodation for plaintiff.