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$1,000 Awarded in Denial of Dental Care in TX
On July 14, 1997, federal magistrate Judith Guthrie held that Texas prison dentists were deliberately indifferent in refusing to provide dental care to a prisoner. Following a bench trial magistrate Guthrie awarded the plaintiff $1,000 in damages. Garmon Coats, a Texas state prisoner, sought to have a broken filling replaced. The Texas Department of Criminal Justice (TDCJ) limits dental care to prisoners who pass a "plaque test," which involves swishing a red liquid solution in the patient's mouth to show the location of plaque on teeth. To pass the test, plaque must be on less than 20% of the teeth. To receive dental care prisoners must pass the plaque test. TDCJ dentists claim they use the test to compel good oral hygiene.
Coats was denied dental care because he repeatedly failed the plaque test. Over an 18 month period Coats submitted over 50 sick call requests seeking care for his tooth. As a result of the delay, the tooth died and prison dentists refused to provide a root canal and a cap, claiming that TDCJ policy prohibited them from doing so and only tooth extractions were allowed. Coats filed suit claiming that prison dentist Joseph Mitchell was deliberately indifferent to his serious medical needs.
The court agreed and ruled that the delay in providing dental care violated Coats' eighth amendment rights. The court awarded Coats $1,000 in damages. The court did not order injunctive relief, but said it would reconsider the matter if care was not provided. Coats litigated the case pro se and informed PLN he was provided with a root canal and a filling in October, 1997 as well as $56 in interest. The state did not appeal the ruling, which is unpublished. See: Coats v. Moore , US DC, ED TX, Tyler Division. Case No. G96CV-283.
Coats was denied dental care because he repeatedly failed the plaque test. Over an 18 month period Coats submitted over 50 sick call requests seeking care for his tooth. As a result of the delay, the tooth died and prison dentists refused to provide a root canal and a cap, claiming that TDCJ policy prohibited them from doing so and only tooth extractions were allowed. Coats filed suit claiming that prison dentist Joseph Mitchell was deliberately indifferent to his serious medical needs.
The court agreed and ruled that the delay in providing dental care violated Coats' eighth amendment rights. The court awarded Coats $1,000 in damages. The court did not order injunctive relief, but said it would reconsider the matter if care was not provided. Coats litigated the case pro se and informed PLN he was provided with a root canal and a filling in October, 1997 as well as $56 in interest. The state did not appeal the ruling, which is unpublished. See: Coats v. Moore , US DC, ED TX, Tyler Division. Case No. G96CV-283.
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Related legal case
Coats v. Moore
| Year | 1996 |
|---|---|
| Cite | US DC, ED TX, Tyler Division Case No. G96CV-283 |
| Level | District Court |
| Conclusion | Bench Verdict |
| Damages | 1000 |
| Injunction Status | N/A |