Richmond v. Huq, et al., No. 16-2560 (DONALD, Moore, Stranch).

Richmond v. Huq, et al., No. 16-2560 (DONALD, Moore, Stranch).

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.

The Sixth Circuit affirmed summary judgment in part, and reversed in part. The Court noted at the outset that failure of jail staff to adhere to a prescribed course of treatment may satisfy the subjective “deliberate indifference” component of an Eighth Amendment violation, but that claims of inadequate treatment—as opposed to claims of a complete lack of any treatment—will generally not suffice unless it is “so woefully inadequate as to amount to no treatment at all.”

The Court then examined each of the plaintiff’s claims against the individual defendants, affirming judgment as to some and reversing as to others after carefully examining the facts relating to each defendant. One important holding was the Court’s rejection of the defendants’ argument that, had the need arisen, the plaintiff could have been admitted to the jail’s mental health inpatient program, finding that “[t]o wait until an inmate with a documented history of mental illness has a psychiatric episode so severe that it requires inpatient treatment before providing her with any psychiatric medication will inevitably result in unnecessary suffering by the inmate. This is the very type suffering the Eighth Amendment aims to prevent.”