8th Cir. Rules for Prison Officials in PTSD Case

(CN) - Nebraska prison officials and medical staff accused of deliberately ignoring an ill prisoner's declining medical condition are entitled to qualified immunity, a divided Eighth Circuit ruled.

Convicted murderer James Saylor, an inmate at the Nebraska State Penitentiary, sued the state department of correctional services, the prison director, and several doctors and psychologists in June 2012, claiming they collectively ignored or failed to adequately deal with complications he was experiencing due to his post-traumatic stress disorder.

Saylor was diagnosed with the condition following a 2002 assault in which he was beaten and raped by other prisoners, an attack for which he ultimately secured a $250,000 judgment against the state of Nebraska and the state Dept. of Correctional Services.

In his latest lawsuit, Saylor claimed his mental state deteriorated after corrections officials decided to transfer him to another prison against his will.

Saylor claims he was so distraught at the prospect of transfer that he attempted to hang himself in his cell while in protective custody.

The defendants moved for summary judgment, claiming they were entitled to qualified immunity and therefore could not be sued for damages individually.

A federal judge in Lincoln. Neb. denied summary judgment to the healthcare professionals, but that decision was overturned by the Eighth Circuit on Friday.

"Throughout his time of incarceration, the record shows that Defendants met Saylor's medical needs beyond the minimum standard required," wrote Chief U.S. Circuit Judge C. Arlen Beam on behalf of the majority of a three-judge panel.

"Defendants were aware of his medical needs and took steps to meet those needs. Because Saylor cannot show that Defendants acted with deliberate indifference, there was no deprivation of his Eighth Amendment rights, and thus, Defendants are entitled to qualified immunity," Beam said.

In a dissenting opinion, U.S. Circuit Judge Jane Kelly found that the evidence demonstrated a genuine dispute relevant to the question of qualified immunity.

"The defendants presented no evidence suggesting that they were unaware of the prior state court judgment," Kelly said.

"For the purposes of the summary judgment analysis, there is no genuine dispute that all the defendants were actually aware of Saylor's serious medical needs and the risk of harm if he were denied adequate care," she said.

Saylor was convicted of second-degree murder in 1984 for his involvement in a murder-for-hire plot to kill his grandmother, according to the Lincoln Journal-Star. He was sentenced to 10 years to life, and remains in prison 32 years later.

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