Clifton v. Eubank

Pamela Clifton (plaintiff) was incarcerated during her pregnancy. Clifton had an appointment with the doctor at the correction facility at the eight-month mark of her pregnancy. The doctor informed Clifton that her pregnancy was proceeding as expected. Clifton began to experience contractions four days later, in the morning of December 25, 1998. Clifton told Officer Dawn Anaya (defendant) that she was going into labor. Anaya sent Clifton back to her unit without taking any further actions or providing Clifton with any medical assistance. At lunchtime, Clifton informed Officer Ira Wilks (defendant) that she was going into labor. Wilks also sent Clifton away and provided no assistance. Clifton then told a third officer that she was in labor and needed medical assistance. The third officer sent Clifton to the medical unit to see Nurse Ilona Eubanks (defendant). Eubanks performed an exam and informed Clifton that the labor was a false alarm because her water had not broken. Clifton asked Eubanks to transport her to the hospital because she had had other pregnancies that required medical assistance prior to the water breaking. Eubanks denied the request and sent Clifton back to her unit, failing to evaluate the fetus using a heart monitor. Clifton remained in distress and was not sent back to the medical unit until the following day. Clifton was transported from the medical unit to the hospital after reporting that she could not feel any fetal movement. Hospital personnel determined that the fetus was dead, and Clifton gave birth to a stillborn. In response, Clifton filed suit against Anaya, Wilks, and Eubanks on the ground that the improper medical care she received violated her constitutional rights. Anaya, Wilks, and Eubanks filed a motion for summary judgment on the ground that the Prison Litigation Reform Act (PLRA) barred Clifton’s claim.