Federal Court upholds inmate's civil rights claim

Jerry Flanory sued the warden and a number of other prison officials, alleging that they should be required to compensate him for extensive dental injuries he suffered when he could not afford to purchase toothpaste.  Over the course of 337 days, the prison officials allegedly denied Flanory toothpaste, and at the end of that period he was diagnosed with serious dental disease related to inadequate hygiene.  According to the Court, officials referred Flanory to the basic hygiene kit provided to all prisoners in denying him indigent status, even though toothpaste wasn't available in the kit and was available only for purchase. The District Court had rejected Flanory's claim and dismissed his suit.

The appellate court determined that prison officials were not entitled to summary disposition and that a trial should be held to assess whether officials demonstrated "deliberate indifference" to Flanory's serious medical needs.  It pointed out that under the Eighth Amendment, it is a violation of a citizen's civil rights to deny appropriate medical care to a prisoner, unless the denial of care relates to a "de minimis" injury or mere negligence.  The court concluded that complete denial of medical care for a period approaching a full year, where the expected outcome is a serious medical condition, can qualify as a civil rights violation under the Eighth Amendment.