Jan 3, 2018

Richmond v. Huq (Amended Opinion), No. 16-2560 (DONALD, Stranch, Moore).

Richmond v. Huq (Amended Opinion), No. 16-2560 (DONALD, Stranch, Moore).

The plaintiff sued a number of defendants, alleging that while she was incarcerated she received constitutionally inadequate treatment for a self-inflicted burn wound and that she was unconstitutionally deprived of her psychiatric medication for over two weeks, in violation of the Eighth Amendment. The district court granted summary judgment for the defendants because the plaintiff had failed to show a constitutional violation. The plaintiff appealed.

On September 20, 2017, the Sixth Circuit affirmed summary judgment in part, and reversed in part. Today, the Court reversed its previous decision in the case with regard to one of the defendants. In this amended opinion, the Court affirmed summary judgment for the psychiatric social worker at the jail. Although the social worker did not review the plaintiff’s chart or otherwise attempt to verify the plaintiff’s claims that she had been on prescription medication prior to entering the jail, the social worker reacted reasonably when she referred the plaintiff for a mental health evaluation. The Court found that this was a “medically reasonable” response, even though the social worker did not personally make an effort to secure the plaintiff’s medications.