Adeyemi v. Lightner
To prevail, on a claim of deliberate indifference to a serious medical need, a plaintiff must establish his medical condition is sufficiently serious and that the defendant possessed a culpable state of mind and failed to provide proper treatment. The pro se plaintiff prisoner, Tyehimba Adeyemi, claimed that the defendant doctors and prison officials were deliberately indifferent to a serious medical need, in violation of his rights. Allegedly, the plaintiff's request for a liver biopsy and vitamin regimen in February 2011 went unheeded, although a previous test conducted in March 2010 had indicated elevated enzyme levels. The plaintiff maintained that he filed several requests, and that the defendants did not schedule an exam or treatment. In Farmer v. Brennan, a 1994 decision, the U.S. Supreme Court wrote that an official acts with deliberate indifference when he "knows of and disregards an excessive risk to inmate health or safety; the official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw that inference." The District Court found that the plaintiff, who apparently assumes he has a damaged liver, failed to establish he suffers from a serious medical condition that requires a liver biopsy. The fact that the plaintiff underwent a test that indicated elevated enzyme levels in 2010 was insufficient to prove that the plaintiff requires a biopsy. "Absent any allegations showing that the plaintiff suffers from a serious medical need," wrote the court, "his claim for deliberate indifference to a serious medical need fails." The court dismissed the plaintiff's complaint, without prejudice.