42 USC § 1983 action alleging deliberate indifference to inmates’ serious medical needs; U.S. Const. amend. VIII; Estelle v. Gamble; Farmer v. Brennan; The objective component; Rhinehart v. Scutt; Deference to the district court’s factual findings after a bench trial; United States v. Demjanjuk; Anderson v. City of Bessemer City

In this § 1983 class action, the court affirmed the district court’s ruling that defendant-Tennessee Department of Corrections’ medical director (Williams) was not deliberately indifferent to plaintiffs-inmates’ serious medical needs by implementing a prioritization guidance procedure to determine which inmates with hepatitis C received direct-acting antivirals. A group of Tennessee prisoners who suffer from hepatitis C sued the Department of Corrections and Williams, claiming that the Department’s procedures for choosing the prisoners who are provided with the very expensive antivirals constituted deliberate indifference to the serious medical needs of those who were not chosen. An advisory committee decides whether an inmate will receive the medication. After a bench trial, the district court found for defendants. Agreeing that the inmates established a “serious medical need," the court then considered whether they showed that Williams “‘so recklessly ignored the risk’ of hepatitis C” when designing and implementing the prioritization guidance procedures, “that he was deliberately indifferent to that risk.” The court reviewed the procedures and concluded that Williams sought to use “the finite resources at his disposal to maximize their benefit for the inmates in his care.” It rejected plaintiffs’ argument that Williams should have asked the legislature for more money when there was no evidence that he could have received more than he had already requested.