Where a detainee alleged that prison officials violated his Eighth Amendment rights by delaying his receipt of noise-cancelling headphones and causing him mental anguish, but he failed to allege facts showing they were aware of a substantial risk that would occur from the delay of the headphones or that the delay caused severe pain or a marked exacerbation of his mental health condition, his suit was dismissed.
Background
Christopher John Meyers, a Virginia detainee at Dillwyn Correctional Center, proceeding pro se, filed this civil rights action pursuant to 42 U.S.C. § 1983, alleging that defendants violated his Eighth Amendment rights by delaying his receipt of noise-cancelling headphones and causing him mental anguish. Defendants filed motions to dismiss for failure to state a claim.
Analysis
Meyers alleges the approximately 20-month delay in the delivery of the headphones “prevented [him] from properly dealing with his mental health needs” and added to his overall stress and anxiety levels. He asserts Dr. Jackson-Woodley recommended, and thought Meyers would benefit from, the use of noise-cancelling headphones in order to reduce anxiety and stress.
Under the Eighth Amendment, “[c]ourts treat an inmate’s mental health claims just as seriously as any physical health claims.” At the motion to dismiss stage, I find that Meyers has alleged sufficient facts that he suffered from a serious medical condition diagnosed by a physician as mandating treatment, and thus, has satisfied the objective prong of the deliberate indifference inquiry.
However, Meyers is unable to satisfy the subjective prong of the deliberate indifference inquiry. He fails to allege facts that show defendants were aware of a substantial risk that would occur from the delay of the headphones or that the delay caused severe pain or a marked exacerbation of his mental health condition.
Meyers states he could not properly deal with his mental health needs but does not assert any facts as to how the delay in the delivery prevented this. Even in his complaints and grievances, Meyers did not inform defendants of any serious mental or emotional harm that the delay had caused or was likely to cause him. Furthermore, Meyers was under the care of a psychology associate and no defendants had medical or mental health expertise, Defendants could lawfully rely on the doctor’s professional judgment in deciding how to safely accommodate the potential harms Meyers’s mental illness posed.
As it specifically relates to a delay in treatment, Meyers has not asserted any claims that the delay by defendants in treatment exacerbated his injury or unnecessarily prolonged his serious pain. Meyers alleges that his stress and anxiety levels increased due to trouble completing the order, but he does not allege any facts to establish when or if defendants became aware of his condition.
I recognize the variety of symptoms that individuals with mental health diagnoses experience. However, Meyers’s allegations pale in comparison to the instances in which courts have found substantial harm, such as “where … a prisoner engaged in self-harm, expressed suicidal ideation, or experienced severe mental health symptoms during the period of delay.” Meyers fails to allege facts that show the delay of noise-cancelling headphones resulted in substantial harm to his mental health, and therefore, he cannot recover under § 1983. Accordingly, I find no basis for concluding any delay in his treatment exacerbated his injury or unnecessarily prolonged serious pain.
Defendants’ motion to dismiss granted.
Meyers v. Ratliffe-Walker, Case No. 7:22-cv-00137, July 28, 2023. WDVA at Roanoke (Ballou). VLW 023-3-438. 9 pp.
l
