Inmate lawsuit is good enough for Rule 8 pleading requirements

One of the conservative Supreme Court justices said years ago that the problem with pro se inmate lawsuits is that the inmates sometimes become litigation machines who file lawsuit after lawsuit because they have nothing better to do. That may be, but sometimes these cases have merit. At a minimum, sometimes these cases are sufficiently pled so the inmates can proceed with their cases. In this case, the Second Circuit says the inmate's complaint is good enough for discovery.

The case is Harnage v. Lightner, issued on February 15. Plaintiff is an inmate in state prison in Connecticut. He wants to sue over the deliberate indifference to his serious medical needs. The district court said the complaint was not sufficiently detailed and did not satisfy the rule that lawsuits must place the defendants on notice of the claims, but the Court of Appeals (Calabrese, Cabranes and Chin) says the plaintiff actually states a claim.

Under Rule 8 of the Federal Rules of Civil Procedure, the complaint must contain "a short and plain statement of the claim showing the pleader is entitled to relief." Under Second Circuit law, the plaintiff must at a minimum "disclose sufficient information to permit the defendant to have a fair understanding of what the plaintiff is complaining about and to know whether there is a legal basis for recovery."

While the complaint in this case does not provide definite or specific dates on which plaintiff's requests for medical treatment were made, or any dates when anyone at the jail ignored his requests, the amended complaint "substantially complies" with Rule 8 because it "identifies discrete defendants and the actions taken by defendants that purportedly violated Harnage's Eighth Amendment rights." In particular, plaintiff alleges that he sought treatment from named staff members and that he did not receive effective treatment for his medical condition, i.e., providing the right prescriptions he had been promised. The failure to provide dates is not fatal under Rule 8 where, as here, the plaintiff does not have access to his medical records. So, while the complaint is not great, "it is not the incomprehensible 'labyrinthian prolixity of unrelated and vituperative charges' that Rule 8 was intended to curb."