Vaughn v. Bassett, et. al.

Overview

(U.S. Court of Appeals for the 5th Circuit, June 10, 2024) The Fifth Circuit Court of Appeals reversed a lower court’s dismissal of inmate Vaughn’s Bivens claim that the warden and others violated the Eighth Amendment by denying him access to necessary medical care. Vaughn, representing himself pro se and in forma pauperis, was injured when he collided with another inmate during a softball game, leaving his nose bleeding and his face “visibly caved in.” Although Vaughn promptly requested medical attention, defendant Basset ordered him back to his room and did not arrange transportation to a hospital. Vaughn was evaluated at a hospital the following day, but defendants Crnkovich and Pence prevented him from following up appropriately, including by neglecting to provide Vaughn’s facial surgeon with his CT images. Despite Vaughn’s repeated requests and urgent need for surgery, defendants Crnkovich and Pence failed to provide him with pain medication and delayed his medical follow up for six weeks, until after his bones had healed, resulting in permanent disfiguration of Vaughn’s face. Without commenting on the merits of his claims, the Court held that Vaughn had properly pled an Eighth Amendment claim for deliberate indifference—a very difficult standard for inmates to meet–because he properly alleged that he sustained a serious injury, that the defendants were aware of his injury, and that had subsequently received delayed and inadequate treatment.  Read the full opinion here.

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