Exam of Dental Case: Prison Lawsuit Must Exhaust PLRA Remedies

As we grow older, our tastes mature. We start eating our broccoli. We prefer good cheese to mystery-flavored jellybeans. Waterparks lose favor as our vacation spot of choice.

One thing that doesn't change? We all hate going to the dentist.

But today, we have a prison lawsuit out of the Eleventh Circuit Court of Appeals in which a Georgia prisoner argued that his rights were violated because he was not allowed to see a dentist.

Randall Bingham, the plaintiff, argued that the Autry State Prison in Pelham, Ga. violated his rights when it ignored his requests for dental treatment, denied him prescribed aspirin, and refused to give him a prison rulebook to help him understand the grievance procedures.

The Prisoner Litigation Reform Act (PLRA) requires prisoners to exhaust administrative remedies in the prison system before bringing a civil rights claim in court. Therefore, Bingham’s prison lawsuit turned on whether he had first exhausted his PLRA remedies.

The Eleventh Circuit ruled that the district court erred in dismissing Bingham’s dental treatment claim because it was not clear whether Bingham had actually exhausted his administrative remedies regarding access to medical care. The matter was remanded to the state court.

The court dismissed Bingham’s remaining claims as frivolous. With regard to the aspirin claim, the court noted that Bingham failed to note a medical need that necessitated the aspirin. On Bingham’s rulebook claim, the Eleventh Circuit Court of Appeals said that Bingham had failed to establish how the denial of an individual rulebook compromised Bingham’s life, liberty, or property interest.

Bingham’s requests seem pretty basic. Why would the prison and district court disregard them? Perhaps because they were buried among Bingham’s other complaints against the prison that he was in “imminent danger” of becoming illiterate from guards asking him how to spell words, becoming a drug addict from drugs sold in prison, and “catching cancer” from inmates using illegal cell phones. Bingham also claimed that the prison caused homosexual activity by confiscating inmates’ Playboy magazines. Sadly, Bingham did not include these claims in his Eleventh Circuit appeal.

Regardless, Bingham has won his right to pursue his dental care challenge and (some) justice will be served.

Related Resources:

• Randall Bingham v. Darlene Thomas (Eleventh Circuit Court of Appeals)
• FindLaw’s Eleventh Circuit blog (FindLaw)
• Jury Trials Not Guaranteed to Hear PLRA Deficiency Excuses (FindLaw’s Second Circuit blog)
• Porn In Prison Lawsuit Dismissed (CBS Detroit)