Brown v. LaVoie

Dist. Ct. erred in granting defendant-prison doctor’s motion for summary judgment in plaintiff-prisoner’s section 1983 action, alleging that defendant violated his 8th Amendment rights by being deliberately indifferent to his medical needs by denying him anesthesia when making two unsuccessful attempts at removing two-inch screw that plaintiff had inserted into his elbow. Record showed that plaintiff experienced pain when defendant attempted to remove embedded screw, and that defendant explained to plaintiff, when denying his request for anesthesia, that “You stuck a screw in your arm, not me, and this is a consequence of your actions.” Ct. of Appeals, in reversing Dist. Ct., found that plaintiff presented sufficient evidence regarding defendant’s culpable state of mind that could support finding of deliberate indifference, especially where record supported finding that defendant did not exercise any medical judgment when denying use of anesthesia, but rather based denial on personal animosity toward plaintiff based on desire to punish plaintiff or otherwise inflict or prolong pain.