Opinion · Supreme Court of the United States
Erickson v. Pardus
551 U.S. 89
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 2007-06-04
- Topic
- general
How later courts describe this case
- concluding that allegations that prison officials stopped administering medication, which endangered the prisoner’s life, and refused to continue treatment despite the need were not "too conclusory”
- holding that courts must liberally construe papers submitted by pro se litigants “to make the strongest arguments they suggest”
- holding that liberal construction of pro se pleadings is required after 12 Ashcroft v. Iqbal, 556 U.S. 662 (2007)
- holding that a district court may reconsider a 24 “final, appealable order[]” under Rule 59(e) or Rule 60(b)
- recognizing that pro se pleadings are “to be liberally construed” and “held to less stringent standards than pleadings drafted by lawyers”
- holding that dismissal was inconsistent with the “liberal pleading standards set forth by Rule 8(a)(2)”
- concluding that prisoner sufficiently pleaded Eighth Amendment deliberate indifference claim based on denial of HCV treatment
- holding that pro se litigant’s filings are to be “liberally construed” and held to less stringent standards than pleadings drafted by lawyers
Citator
Erickson v. Pardus is good law as far as the corpus records: followed by 2 later decisions, and nothing recorded condemns it.
- Authority status
- positive
- Cited by
- 34330 opinions
- Followed
- 2 times
Headnotes
- Civil Procedure — Pleading Federal Rule of Civil Procedure 8(a)(2) requires only a short and plain statement of the claim showing that the pleader is entitled to relief; specific facts are not necessary, so long as the statement gives the defendant fair notice of what the claim is and the grounds upon which it rests.
- Civil Procedure — Motion to Dismiss When ruling on a defendant's motion to dismiss, a judge must accept as true all of the factual allegations contained in the complaint.
- Civil Procedure — Pro Se Pleadings A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.
- Civil Rights Law — Deliberate Indifference Deliberate indifference to the serious medical needs of prisoners constitutes the unnecessary and wanton infliction of pain proscribed by the Eighth Amendment, and includes indifference manifested by prison doctors in their response to the prisoner's needs or by prison guards in intentionally denying or delaying access to medical care or intentionally interfering with treatment once prescribed.
- Civil Rights Law — Eighth Amendment Future Harm The Eighth Amendment protects against future harm to an inmate, and a prisoner may state an Eighth Amendment claim where he alleges that the denial or delay of medical treatment has resulted in a life-threatening situation or has exacerbated his medical problems.
- Civil Procedure — Sufficiency of Allegations of Harm A prisoner's allegations that the termination of his prescribed medication for a serious disease endangered his life and caused him continued damage to his liver are sufficient to satisfy the pleading standard of Rule 8(a)(2); such allegations cannot be dismissed as too conclusory on the ground that they fail to establish a cognizable independent harm.
Imprisoned by the State of Colorado and alleging violations of his Eighth and Fourteenth Amendment protections against cruel and unusual punishment, William Erickson, the petitioner in this Court, filed suit against prison officials in the United States District Court for the District of Colorado. He alleged that a liver condition resulting from hepatitis C required a treatment program that officials had commenced
Petitioner was incarcerated in the Limón Correctional Facility in Limón, Colorado, where respondents Barry Pardus and Dr. Anita Bloor were working as prison officials. After Dr. Bloor removed petitioner from the hepatitis C treatment he had been receiving, petitioner sued under Rev. Stat. § 1979, 42 U. S. C. § 1983, complaining, inter alia, that Dr. Bloor had violated his Eighth Amendment rights by demonstrating deliberate indifference to his serious medical needs. See, e. g., Estelle v. Gamble, 429 U. S. 97, 104-105 (1976) (“[Deliberate indifference to serious medical needs of prisoners constitutes the unnecessary and wanton infliction of pain . .. proscribed by the Eighth Amendment,” and this includes “indifference . . . manifested by prison doctors in their response to the prisoner’s needs or by prison guards in intentionally denying or delaying access to medical care or intentionally interfering with the treatment once prescribed” (footnotes and internal quotation marks omitted)); see also Helling v. McKinney, 509 U. S. 25, 35-37 (1993).
Petitioner based his claim on the following1 allegations, which we assume to be true for purposes of review herd: Officials at Colorado’s Department of Corrections (Department) diagnosed petitioner as requiring treatment for hepatitis C. After completing the necessary classes arid otherwise complying with the protocols set forth by the Department, petitioner began treatment for the disease. The treatment, which would take a year to complete, involved weekly self-injections of medication by use of a sy
Prison officials, disbelieving petitioner’s claim not to have taken the syringe, found that his conduct constituted a violation of the Colorado Code of Penal Discipline for possession of drug paraphernalia. Letter from Anthony A. DeCesaro to William Erickson (Sept. 30,2004), attached to Petitioner’s Complaint. This conduct, according to the officials, led to the “reasonable inference” that petitioner had intended to use drugs, so the officials removed petitioner from his hepatitis C treatment. Ibid. “The successful treatment of Hepatitis C is incumbent upon the individual remaining drug and alcohol free to give the liver a better chance of recovery,” they indicated, ibid., an explanation they later offered to defend against petitioner’s allegations of cruel and unusual punishment, see Defendants’ Motion to Dismiss in Civ. Action No. 05-CV-00405-LTB-MJW, p. 10. Assuming that a person in the course of this treatment takes illicit drugs, the prison’s protocol mandates a waiting period of one year followed by a mandatory drug education class lasting six months. Brief in Opposition 4. Petitioner therefore could face a delay of some 18 months before he would be able to restart treatment.
In his complaint petitioner alleged Dr. Bloor had “removed [him] from [his] hepatitis C treatment” in violation of Department protocol, “thus endangering [his] life.” Petitioner’s Complaint 2. Petitioner attached to the complaint certain grievance forms. In these he claimed, among other things, he was suffering from “continued damage to [his] liver” as a result of the nontreatment. Colorado Dept, of Corrections
Three months after filing his complaint, and well before the District Court entered a judgment against him, petitioner filed a Motion for Expedited Review Due to Imminent Danger in Civ. Action No. 05-B-405 (M JW) (D. Colo.). Indicating it was “undisputed” that he had hepatitis C, that he met the Department’s standards for treatment of the disease, and that “fiirtherance of this disease can cause irreversible damage to [his] liver and possible death,” petitioner alleged that “numerous inmates” in his prison community had died of the disease and that he was “in imminent danger” himself “due to [the Department’s] refusal to treat him.” Ibid. He had identified similar allegations in an earlier filing, explaining that “his liver is suffering irreversible damage” due to the decision to remove him from treatment and that he “will suffer irreparable damage if his disease goes untreated.” Plaintiff’s Objections to the Magistrate’s Recommendations in Civ. Action No. 05-CV-00405-LTB-MJW (Feb. 27, 2005), p. 3.
Respondents answered these filings with a motion to dismiss. The Magistrate Judge recommended, as relevant, that the District Court dismiss the complaint on the ground it failed to allege Dr. Bloor’s actions had caused petitioner “substantial harm.” Recommendation on Defendants’ Motion to Dismiss (Feb. 9, 2006), p. 12. The District Court issued a short order indicating its agreement with the Magistrate Judge and dismissing the complaint.
The Court of Appeals affirmed. It quoted extensively . from the Magistrate Judge’s discussion of “substantial harm” before holding that petitioner had made “only conclusory allegations to the effect that he has . suffered a cognizable independent harm as a result of his removal from the [hep
It may in the final analysis be shown that the District Court was correct to grant respondents’,motion to dismiss. That is not the issue here, however. It was error for the Court of Appeals to conclude that the allegations in question, concerning harm caused petitioner by the termination of his medication, were too conclusory to establish for pleading purposes that petitioner had suffered “a cognizable independent harm” as a result of his removal from the hepatitis C treatment program. Id., at 698.
Federal Rule of Civil Procedure 8(a)(2) requires only “a short and plain statement of the claim showing that the pleader is entitled to relief.” Specific facts are not necessary; the statement need only “ ‘give the defendant fair notice of what the . .. claim is and the grounds upon which it rests.’” Bell Atlantic Corp. v. Twombly, 550 U. S. 544, 555 (2007) (quoting Conley v. Gibson, 355 U. S. 41, 47 (1957)). In
The complaint stated that Dr. Bloor’s decision to remove petitioner from his prescribed hepatitis C medication was “endangering [his] life.” Petitioner’s Complaint 2. It alleged this medication was withheld “shortly after” petitioner had commenced a treatment program that would take one year, that he was “still in need of treatment for this disease,” and that the prison officials were in the meantime refusing to provide treatment. Id., at 3, 4. This alone was enough to satisfy Rule 8(a)(2). Petitioner, in addition, bolstered his claim by making more specific allegations in documents attached to the complaint and in later filings.
The Court of Appeals’ departure from the liberal pleading standards set forth by Rule 8(a)(2) is even more pronounced in this particular case because petitioner has been proceeding, from the litigation’s outset, without counsel. A document filed pro se is “to be liberally construed,” Estelle, 429 U. S., at 106, and “a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers,” ibid, (internal quotation marks omitted). Cf. Fed. Rule Civ. Proe. 8(f) (“All pleadings shall be so construed as to do substantial justice”).
Whether petitioner’s complaint is sufficient in all respects is a matter yet to be determined, for respondents raised multiple arguments in their motion to dismiss. In particular, the proper application of the controlling legal principles to the facts is yet to be determined. The case cannot, however, be dismissed on the ground that petitioner’s allegations of harm were too conclusory to put these matters in issue. Certiorari and leave to proceed in forma pauperis are granted, the judgment of the Court of Appeals is vacated,
It is so ordered.
Justice Scalia would deny the petition for a writ of certiorari.