Erickson v. Pardus

PETITIONER: William Erickson
RESPONDENT: Barry J. Pardus, et al.
LOCATION: Limon Correctional Facility

DOCKET NO.: 06-7317
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Tenth Circuit

CITATION: 551 US 89 (2007)
DECIDED: Jun 04, 2007
GRANTED: Jun 04, 2007

Facts of the case

William Erickson was diagnosed with Hepatitis C while imprisoned at Limon Correctional Facility in Limon, Colorado. He was prescribed medication to be administered via injection. One of the syringes he used for injection went missing from the medical center of the correctional facility and was later found in a communal trash can. Erickson was accused of stealing the syringe and utilizing it for illegal drug use, after which he was denied further treatment. Erickson sued prison medical officials under 42 U.S.C. 1983 and argued that the refusal of medical treatment violated his Eighth Amendment rights because he was suffering liver damage and threat of death by not being treated for Hepatitis C. The trial court dismissed Erickson’s suit on the grounds that he could not prove he was suffering substantial harm because he was being denied medical treatment. The U.S. Court of Appeals for the Tenth Circuit affirmed.

Question

Can a plaintiff properly allege he suffered substantial harm as a result of being denied medical treatment while incarcerated for the purposes of a claim under 42 U.S.C. 1983?