Cupit v. Jones
| Decision Date | 24 December 1987 |
| Docket Number | No. 87-4432,87-4432 |
| Citation | 835 F.2d 82 |
| Parties | Milton Eugene CUPIT, Plaintiff-Appellant, v. James "Sonny" JONES, et al., Defendants-Appellees. |
| Court | U.S. Court of Appeals — Fifth Circuit |
Milton E. Cupit, pro se.
William R. Coenen, Jr., Rayville, La., for defendants-appellees.
Appeal from the United States District Court for the Western District of Louisiana.
Before BROWN, JOHNSON, and HIGGINBOTHAM, Circuit Judges.
Plaintiff Milton Eugene Cupit appeals an order by the district court granting defendants' motion for summary judgment and dismissing Cupit's section 1983 civil rights claim against Richland Parish prison officials with prejudice. In entering its order, the district court relied on the report and recommendation of the magistrate prepared after an evidentiary hearing was conducted on Cupit's claim. On appeal, Cupit alleges that the district court's decision was not warranted by the evidence, and that he was improperly denied appointment of counsel. Furthermore, Cupit alleges that the magistrate erred in denying his request that subpoenas be issued for several witnesses and that certain jail documents be produced. Having considered the record before us, we reject Cupit's contentions and affirm.
In April 1985, plaintiff Cupit was arrested and subsequently detained at the Richland Parish Jail. Thereafter, on June 7, 1986, Cupit was convicted of second-degree murder and sentenced to life imprisonment without the benefit of parole, probation, or suspension and was transferred to the Louisiana Department of Corrections system.
On October 9, 1985, Cupit filed the instant section 1983 claim against Richland Parish Jailer James "Sonny" Jones, Sheriff Laurell Graham, and the Richland Parish Police Jury. In his complaint, Cupit alleged that prior to his arrest, he had suffered a major heart attack on January 19, 1985, after which he had heart surgery at E.A. Conway Hospital in Monroe, Louisiana, and at the L.S.U. Medical Center and V.A. Hospitals in Shreveport. Cupit further alleged that during the time he was a pretrial detainee at Richland Parish Jail, he was denied proper medical attention for his heart condition as he was not provided the requisite diet, exercise, medication and stress-free atmosphere recommended by his doctors. As damages for the alleged deprivations, Cupit requested $1,000 per day plus interest for the period he was confined at Richland Parish Jail and also requested that the defendant prison officials be placed under a court order to comply with his doctors' instructions.
Thereafter, the defendants filed a motion for summary judgment asserting that they did not have any specific knowledge of the requirements for Cupit's special diet or exercise, but when they were notified from medical personnel that such instructions did exist, they adhered to those instructions. Cupit then filed an opposition to the motion for summary judgment after which the magistrate determined that there was a genuine issue as to material facts; therefore, an evidentiary hearing to supplement the affidavits and exhibits of the parties was scheduled for April 10, 1986. Prior to the hearing, Cupit requested that the magistrate appoint counsel to assist him in the presentation of his claim. The magistrate denied Cupit's motion for counsel on May 28, 1986. As a result, Cupit appeared pro se at the evidentiary hearing. In addition to denying Cupit's motion for appointment of counsel, the magistrate denied a request by Cupit that subpoenas be issued for several witnesses and that certain jail documents be produced.
Following the evidentiary hearing on April 10, the magistrate recommended dismissal with prejudice of Cupit's complaint, determining that Cupit's claims of denial of proper exercise, medication, diet and stress-free atmosphere were not supported by the evidence. Specifically, the magistrate found that Cupit did not show that Richland Parish prison officials acted with deliberate indifference to his medical needs. In making his conclusions, the magistrate relied on the standard of medical care due prisoners espoused by the Supreme Court in Estelle v. Gamble, 429 U.S. 97, 97 S.Ct. 285, 50 L.Ed.2d 251 (1976). On May 26, 1987, the district court, after an independent review of the record and objections filed by Cupit, ordered that the defendants' motion for summary judgment be granted and the civil rights complaint of Cupit be dismissed with prejudice. Cupit appeals the district court's order.
Initially, Cupit argues that the magistrate erred in determining that prison officials were not deliberately indifferent to his needs for special medical care, diet, exercise, and stress-free atmosphere. We note that the time frame for which plaintiff is seeking damages for the alleged deprivations is that period of time when he was a pretrial detainee at Richland Parish Jail, not a convicted prisoner who had already been adjudicated guilty. Pretrial detainees, as opposed to convicted prisoners, are those individuals who have been charged with a crime but who have not yet been tried on the charge. Bell v. Wolfish, 441 U.S. 520, 523, 99 S.Ct. 1861, 1865, 60 L.Ed.2d 447 (1979). We highlight the distinction between pretrial detainees and convicted prisoners because the due process clause of the fourteenth amendment accords pretrial detainees rights not enjoyed by convicted inmates under the eighth amendment prohibition against cruel and unusual punishment. Jones v. Diamond, 636 F.2d 1364, 1368 (5th Cir.1981) (en banc), overruled on other grounds, 790 F.2d 1174 (1986). Specifically, "while a sentenced inmate may be punished in any fashion not cruel and unusual, the due process clause forbids punishment of a person held in custody awaiting trial but not yet adjudged guilty of any crime." Id.
In Bell v. Wolfish, the Supreme Court determined that as to pretrial detainees, the proper inquiry under the due process clause is whether conditions accompanying pretrial detention are imposed upon detainees for the purpose of punishment, as the due process clause does not permit punishment prior to an adjudication of guilt. Bell, 441 U.S. at 535, 99 S.Ct. at 1871.
Thus, if a particular condition or restriction of pretrial detention is reasonably related to a legitimate governmental objective, it does not, without more, amount to punishment. Conversely, if a restriction or condition is not reasonably related to a legitimate goal--if it is arbitrary or purposeless--a court permissibly may infer that the purpose of the governmental action is punishment that may not constitutionally be inflicted upon detainees qua detainees.
Id. at 539, 99 S.Ct. at 1874. This Circuit has applied the Bell v. Wolfish criterion to medical attention for pretrial detainees, stating, "[t]he Bell v. Wolfish criterion, applied to medical attention, entitles pretrial detainees to reasonable medical care unless the failure to supply it is reasonably related to a legitimate governmental objective." Jones, 636 F.2d at 1378.
In a recent decision by this Court, Partridge v. Two Unknown Police Officers of Houston, 791 F.2d 1182 (5th Cir.1986), the Court held that prison officials had a duty, at a minimum, not to be deliberately indifferent to [the plaintiff's] serious medical needs. Id. at 1187. Today, we conclude that pretrial detainees are entitled to reasonable medical care unless the failure to supply that care is reasonably related to a legitimate governmental objective. Furthermore, pretrial detainees are entitled to protection from adverse conditions of confinement created by prison officials for a punitive purpose or with punitive intent. We perceive this holding to be consistent with the criterion for conditions imposed on pretrial detainees set forth by the Supreme Court in Bell v. Wolfish. 1 In so holding, we recognize that the distinction as to medical care due a pretrial detainee, as opposed to a convicted inmate, may indeed be a distinction...
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