Charles Pruitt, Jr. v. Sandra Lake and Majorie Parrott Hall

CourtDistrict Court, E.D. Arkansas
DecidedApril 8, 2026
Docket3:24-cv-00186
StatusUnknown

This text of Charles Pruitt, Jr. v. Sandra Lake and Majorie Parrott Hall (Charles Pruitt, Jr. v. Sandra Lake and Majorie Parrott Hall) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charles Pruitt, Jr. v. Sandra Lake and Majorie Parrott Hall, (E.D. Ark. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

CHARLES PRUITT, JR. PLAINTIFF ADC #091574

V. NO. 3:24-cv-186-DPM-ERE

SANDRA LAKE and MAJORIE PARROTT HALL DEFENDANTS

RECOMMENDED DISPOSITION

I. Procedure for Filing Objections This Recommended Disposition (“RD”) has been sent to United States District Judge D.P. Marshall Jr. You may file written objections to all or part of this RD. If you do so, those objections must: (1) specifically explain the factual and/or legal basis for your objection; and (2) be received by the Clerk of this Court within 14 days of the date of this RD. If you do not file objections, you may waive the right to appeal questions of fact. II. Background Pro se plaintiff Charles Pruitt, Jr., an Arkansas Division of Correction (“ADC”) inmate, filed this 42 U.S.C. § 1983 case. Doc. 2. Mr. Pruitt is currently proceeding on medical deliberate indifference claims against Defendants APN/Health Services Administrator Sandra Lake and LPN/Health Services Administrator Majorie Parrott Hall in their individual and official capacities seeking declaratory, monetary, and injunctive relief.1

On February 11, 2026, Mr. Pruitt filed a motion for summary judgment.2 Doc. 64. On February 13, 2026, Defendants filed a motion for summary judgment, a

brief in support, and a statement of undisputed facts. Docs. 66, 67, 68. Mr. Pruitt has responded to Defendants’ motion, which is now ripe for review. Docs. 70, 71. For the following reasons, I recommend granting Defendants’ motion for summary judgment (Doc. 66) and denying Mr. Pruitt’s motion for summary

judgment (Doc. 64).

1 The Court previously dismissed Mr. Pruitt’s claims against ADC Deputy Director Aundrea Culclager based on his failure to state a constitutional claim for relief against Defendant Culclager. Doc. 33. As explained below, Defendants are entitled to judgment as a matter of law on Mr. Pruitt’s individual capacity claims. As a result, Mr. Pruitt’s official capacity claims also fail because there is no underlying constitutional violation to support them. In addition, Mr. Pruitt fails to allege that he suffered any constitutional injury as a result of a Wellpath policy, plan, or custom. Burke v. North Dakota Dept. of Corrs. & Rehab., 294 F.3d 1043, 1044 (8th Cir. 2002). A corporation can be held liable only if it had unconstitutional policies or practices that caused Mr. Pruitt’s injuries. Id.; Johnson v. Hamilton, 452 F.3d 967, 973 (8th Cir. 2006); Sanders v. Sears Roebuck & Co., 984 F.2d 972, 975-976 (8th Cir. 1993).

2 In his motion for summary judgment, Mr. Pruitt fails to make any argument regarding why he is entitled to judgment as a matter of law on the claims raised in this lawsuit, rather he only refers to specific evidence that he filed with the Court. Doc. 63. I have reviewed that evidence and include it in my analysis of Mr. Pruitt’s medical deliberate indifference claims. See Section III, B. Factual Evidence. III. Discussion A. Summary Judgment Standard

Summary judgment is appropriate when the record, viewed in a light most favorable to the nonmoving party, demonstrates that there is no genuine dispute as to any material fact, and the moving party is entitled to judgment as a matter of law.

See FED. R. CIV. P. 56(a); Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986); Anderson v. Liberty Lobby Inc., 477 U.S. 242, 249-50 (1986). The moving party bears the initial burden of demonstrating the absence of a genuine dispute of material fact. Celotex, 477 U.S. at 323. Once that has been done, the nonmoving party must

come forward with specific facts demonstrating that there is a material dispute for trial. See FED. R. CIV. P. 56(c); Torgerson v. City of Rochester, 643 F.3d 1031, 1042 (8th Cir. 2011). A party is entitled to summary judgment if -- but only if -- the

evidence shows that there is no genuine dispute about any fact important to the outcome of the case. See FED. R. CIV. P. 56; Odom v. Kaizer, 864 F.3d 920, 921 (8th Cir. 2017). B. Factual Evidence3

On May 16, 2023, at the North Central Unit, Defendant Lake examined Mr. Pruitt, who complained of reeling and cracking on his right hand and left foot.

3 Unless otherwise noted, these facts are from: (1) Dr. Nicholas Gowen’s affidavit (Doc. 68-4); and (2) Mr. Pruitt’s medical records. Docs. 63; 68-1 through 68-3; 68-4 through 68-13. Defendant Lake noted dry cracking skin and ordered Absorbase ointment. Doc. 68- 1 at 1.

On August 7, 2023, Mr. Pruitt was transferred to the Ester Unit.4 On August 15, 2023, non-party Dr. Ronald Stukey saw Mr. Pruitt at a chronic- care visit and noted that Mr. Pruitt’s condition was stable and that he was “generally

well.” Doc. 68-2 at 1-2. Dr. Stukey ordered medications and follow-up lab tests. Id. On October 2, 2023, non-party LPN Gary Landreth saw Mr. Pruitt during sick call for skin complaints. Doc. 63 at 22-23. Nurse Landreth noted, “treatment not working[,] area getting worse on Right hand and Left foot[,] and skin peeling off

bumps under skin.”5 Id. at 23. Nurse Landreth referred Mr. Pruitt to the provider. Id. On October 4, 2023, Dr. Stukey evaluated Mr. Pruitt for complaints of a rash on his right hand and the left sole of his foot. Doc. 68-3 at 1. Dr. Stukey noted

moderate thickening and some scaling to Mr. Pruitt’s right palm and left sole of the foot with occasional darkened spots. Id. Dr. Stukey ordered Triamcinolone Acetonide for treatment of possible dyshidrotic eczema. Id. On November 14, 2023, Nurse Landreth saw Mr. Pruitt at a sick-call visit.

Doc. 63 at 89. During that encounter, Mr. Pruitt complained that Dr. Stukey

4 Although Defendants do not cite any evidence to support this factual allegation, Mr. Pruitt does not contest this fact (Doc. 71 at 2), nor is it material to the facts at issue. 5 Mr. Pruitt’s medical records do not specify whether those complaints were made by Mr. Pruitt or whether those notations were Nurse Landreth’s personal observations. “erroneously” concluded that his skin complaints were stress related. Id. Nurse Landreth instructed Mr. Pruitt to “follow up as needed.” Id.

On November 16, 2023, Dr. Stukey saw Mr. Pruitt during a chronic-care visit and noted that Mr. Pruitt was clinically stable. Doc. 68-5 at 1. On December 21, 2023, Mr. Pruitt had an interactive telemedicine encounter

with non-party David Ford. Doc. 63 at 49. During that encounter, Mr. Pruitt again complained about a fungal infection on his hands. Medical staff referred Mr. Pruitt to an on-site provider for a skin exam. Id. On December 28, 2023, Dr. Stukey examined Mr. Pruitt for complaints of a

possible fungal infection. Doc. 68-6 at 1. Dr. Stukey noted small blisters on Mr. Pruitt’s palms consistent with dyshidrotic eczema. Id. He ordered Betamethasone Diproplonate cream, encouraged Mr. Pruitt to avoid scratching the “blister like

areas,” and explained why the lesions were not fungal. Id. On January 24, 2024, non-party Dr. Shawn Anderson saw Mr. Pruitt at a follow-up visit. Doc.

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