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Adamson v. Correctional Medical Services6/14/2000
o provide Petitioner with any remedy in the nature of damages.
Respondent presents essentially two arguments why Petitioner must exhaust available administrative remedies before filing a civil action in state court. First, Respondent states that under the principles of statutory construction, coupled with the specific legislative history of the statute involved, the PLA's administrative exhaustion requirement plainly encompasses prisoner malpractice lawsuits filed against private contractors. Respondent focuses in particular on the defined statutory term "civil action," stating:
Four elements comprise the principal definition of "civil action" under the Act. To be a "civil action," an action must be: (1) a legal action (2) seeking money damages, injunctive relief, or any appeal (3) filed in any court in the State (4) that relates to or involves a prisoner's conditions of confinement. See § 5-1001(c)(1). Petitioner's actions against [Respondent] in the district court and the circuit court satisfy each of those elements. Petitioner filed his lawsuit against [Respondent] in the district court, then appealed to the circuit court, alleging that [Respondent] "recklessly and negligencly failed to provide adequate medical care for the Plaintiff's painful Anterior crucrate ligarment repair of his right knee. . . ." Plaintiff sought damages of $2,500.00. Certainly this case is a legal action, seeking money damages, filed in a court in this State.
A crux of Respondent's argument lies in its conception of the statutory term "conditions of confinement." It asserts that Petitioner's malpractice claim relates to a "condition of confinement" by referencing Supreme Court jurisprudence and several federal court decisions. It states:
In Wilson v. Seiter, 501 U.S. 294 (1991), for example, the Court held that claims arising from prison-wide deprivations, and deprivation of medical care to an individual prisoner, were actions addressing "conditions of confinement":
he medical care a prisoner receives is just as much a "condition" of his confinement as the food he is fed, the clothes he is issued, the temperature he is subjected to in his cell, and the protection he is afforded against other inmates. Id. at 303.
Federal courts have dismissed prisoner lawsuits relating to medical services, construing the [federal Prison Litigation Reform Act] to require prisoners to exhaust all administrative remedies before filing suits relating to "prison conditions."
Respondent then cites several federal court cases to support its proposition and notes that the PLA was enacted in 1997 to complement the Federal Prison Litigation Reform Act (PLRA), Pub. L. No. 104-134, 110 Stat. 1321, § 801-10, signed into law on 26 April 1996. The PLRA was designed to discourage frivolous lawsuits and to slow the tide of lawsuits filed in federal courts for grievances relating to prisoners' confinement. The federal statute used several mechanisms to achieve these goals, namely to require the payment of a filing fee, to limit the types of actions that may be filed, to limit attorney's fees, to empower judges to determine and dismiss frivolous suits, and to require the exhaustion of administrative remedies before a prisoner may seek independent judicial intervention by way of a civil action. Respondent reasons that since the PLA was formulated after the PLRA and that the federal courts have determined that the delivery of medical services in correctional institutions is a "condition of confinement", Petitioner's lawsuit relates to a "condition of confinement" and thus is subject to the administrative procedures of the DOC, and perhaps the IGO, through the exhaustion requirement
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