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Supreme Court Decision Update - Erikson v. Pardus

hepatitis_c_virus.jpgDamned Supreme Court — they’re a bunch of teases is what they are. In Erikson v. Pardus (PDF of the Opinion), the Supremes laid out a relatively interesting set of facts, and then never addressed the merits of the case because the damn issue concerns a technical pleading matter. Well, for lack of anything better to do, I’ll also set out the facts and then perform a magic trick by instantly making your eyes glaze over.

The case concerns William Erickson, an inmate imprisoned by the state of Colorado. He has Hepatitis C, a life endangering disease. As such, the doctors at the prison began treating him for it — the treatment required a series of self-injections. However, soon after treatment began, the doctors suspended it when they discovered one of the syringes in a communal trash can and concluded that Erikson was using it to inject illicit drugs. He denied this, of course, and then sued the state on 8th Amendment grounds, alleging that the state’s decision to withhold treatment was cruel and unusual punishment.

However, both the district court and the 10th Circuit threw out the case in summary judgment, holding that Erikson’s pleadings only included “conclusory allegations to the effect that he has suffered a cognizable independent harm as a result of his removal from the [hepatitis C] treatment program.” The Supremes, in a per curiam opinion, noted that “Federal Rule of Civil Procedure 8(a)(2) requires only ‘a short and plain statement of the claim showing that the pleader is entitled to relief.’ Specific facts are not necessary; the statement need only ‘give the defendant fair notice of what the … claim is and the grounds upon which it rests.’

In other words, the Supremes were, like, “Stop being douchebags. This guy was representing himself, so lay off — he did as well as he could, so at least listen to the man’s case — the dude probably doesn’t even know what ‘conclusory’ means.”

Scalia departed from the per curiam opinion, noting that he wouldn’t have granted cert in the first place, while Thomas dissented, noting that the 8th Amendment only applies to “injuries relating to a criminal sentence.”