Tipton v. Ohio State University Hospital

CourtDistrict Court, S.D. Ohio
DecidedFebruary 2, 2021
Docket2:20-cv-04848
StatusUnknown

This text of Tipton v. Ohio State University Hospital (Tipton v. Ohio State University Hospital) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tipton v. Ohio State University Hospital, (S.D. Ohio 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

GARY TIPTON, : CASE NO.: 20cv-4848

: JUDGE MORRISON Plaintiff, : MAGISTRATE VASCURA v. : OHIO STATE UNIVERSITY HOSPITAL, et al., : Defendants.

OPINION AND ORDER

This matter is before the Court for consideration of an Order and Report and Recommendation (R&R) issued by the Magistrate Judge on December 13, 2020. (ECF No. 7). In key part, the R&R recommends full dismissal of this action under 28 U.S.C. § § 1915(e)(2)(b) and 1915A(b) for failure to state a claim upon which relief may be granted. Id. at 1. Pro se Plaintiff Gary Tipton, an Ohio inmate, objects.1 (ECF No. 14.) BACKGROUND The R&R correctly set forth an overview of this action as follows: According to Plaintiff’s Complaint, on January 24, 2020, he was taken to Ohio State University Hospital for a “self-inflicted abdominal wound with an insertion of

1 Mr. Tipton’s Objection was due by December 17, 2020. His Objection was not filed until January 7, 2021. Because the Court prefers deciding issues on the merits, and because his Objection in related case number 20cv-4843 was timely, the Court shall address his untimely Objection in this case. foreign body (razor blades).” Several doctors and nurses (identified as “OSU Hospital ER Doctor John Doe,” “OSU Hospital Charge Nurse John Doe,” and “OSU Hospital Nurse Jane Doe” in the Complaint) evaluated and spoke with Plaintiff. When hospital staff told Plaintiff that his x-rays were negative for any foreign bodies in his abdominal cavity, Plaintiff alleges he used his own fingers to extract a razor blade from his abdominal cavity, showed to hospital staff, and then swallowed it. After another round of x-rays came back negative, Plaintiff was discharged from the hospital. Plaintiff alleges that hospital staff refused to bandage his abdominal wound and Plaintiff further injured himself by roughly removing an IV from his arm. Plaintiff contends he “should never have been able to leave in this condition” because he was suicidal, mentally unstable, and a danger to himself. Plaintiff seeks both punitive and compensatory damages against Ohio State University Hospital and against the Doe Defendants in their individual capacities for alleged “reckless or callous indifference to [Plaintiff’s] rights” and “pain and suffering, mental abuse and neglect.”

(ECF No. 7 at 3.) After granting Mr. Tipton’s IFP motion, the Magistrate held his medical malpractice claims against Ohio State University Hospital were subject to dismissal pursuant to Eleventh Amendment immunity. Id. at 6. The R&R further recommended dismissal of his medical malpractice claims against the individual defendants because the Court lacks jurisdiction as to those defendants. Id. at 6-7. And, assuming that the Complaint asserted a 42 U.S.C. § 1983 deliberate indifference claim, the R&R suggested dismissal of that count as well without prejudice because “Plaintiff’s allegations fall short of the unnecessary and wanton infliction of pain required for an Eighth Amendment claim.” Id. at 8 (citing Jones v. Muskegon Cty., 625 F.3d 935, 941 (6th Cir. 2010)). The R&R lastly determined that Mr. Tipton’s Motion to Appoint Counsel was moot. Id. at 9. STANDARD OF REVIEW

The federal in forma pauperis statute, 28 U.S.C. § 1915, “is designed to ensure that indigent litigants have meaningful access to the federal courts.” Neitzke v. Williams, 490 U.S. 319, 324 (1989) (citation omitted). Because a nonpaying litigant “lacks an economic incentive to refrain from filing frivolous, malicious, or repetitive lawsuits,” 28 U.S.C. § 1915(e) provides in pertinent part: (2) Notwithstanding any filing fee, or any portion thereof, that may have been paid, the court shall dismiss the case at any time if the court determines that—

(A) The allegation of poverty is untrue; or

(B) The action or appeal—

(i) is frivolous or malicious;

(ii) fails to state a claim on which relief may be granted; or

(iii) seeks monetary relief against a defendant who is immune from such relief.

28 U.S.C. § 1915(e)(2). Similarly, 28 U.S.C. § 1915A requires courts to screen complaints to “identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint—is frivolous, malicious, or fails to state a claim upon which relief may be granted.” The same “dismissal standard articulated in Iqbal and Twombly governs dismissals for failure to state a claim under [28 U.S.C. § 1915(e)(2) and 28 U.S.C. § 1915A] because the relevant statutory language tracks the language of Rule 12(b)(6).” Hill v. Lappin, 630 F.3d 468, 470-471 (6th Cir. 2010). Thus, the Court must construe the complaint in the light most favorable to the plaintiff and

determine whether the factual allegations present a plausible claim. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). See also Ashcroft v. Iqbal, 556 U.S. 662 (2009) (clarifying the plausibility standard articulated in Twombly). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. Although a plaintiff’s complaint need

not contain “detailed” factual allegations, its “[f]actual allegations must be enough to raise a right to relief above the speculative level on the assumption that all the allegations in the complaint are true.” Twombly, 550 U.S. at 555. In other words, a complaint is not sufficient if it “tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 557). However, “[p]ro se complaints are to be held ‘to less stringent standards than formal pleadings drafted by lawyers,’ and should therefore be construed liberally.” Garrett

v. Belmont County Sheriff’s Dep’t, 374 Fed. Appx. 612, 614 (6th Cir. 2010) (quoting Haines v. Kerner, 404 U.S. 519, 520 (1972)). ANALYSIS Plaintiff’s Objection (ECF No. 8) incorporates his Objection filed in related case 20cv-4843 (ECF No. 14). Mr. Tipton states that his Complaint is meant to also assert a claim against Defendants under the Emergency Medical Treatment and Active Labor Act (EMTALA), 42 U.S.C. § 1395dd. (ECF No. 8 at 1-2.) The act “places obligations of screening and stabilization upon hospitals and emergency rooms that receive patients suffering from an ‘emergency medical condition.’”

Roberts v. Galen of Va., Inc., 525 U.S. 249, 250 (1999).

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Related

Jeremy Garrett v. Belmont County Sheriff's Dep't
374 F. App'x 612 (Sixth Circuit, 2010)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Jones v. Muskegon County
625 F.3d 935 (Sixth Circuit, 2010)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Roberts v. Galen of Virginia, Inc.
525 U.S. 249 (Supreme Court, 1999)

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Tipton v. Ohio State University Hospital, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tipton-v-ohio-state-university-hospital-ohsd-2021.