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Paruresis No Excuse for Failure to Urinate Absent Medical Verification
Oregon State pro se prisoner Richard Sheeny appealed a U.S. District Court grant of summary judgment to prison officials denying his 42 U.S.C. § 1983 action. He alleged constitutional violations when he was disciplined for failure to urinate because he suffered from shy bladder syndrome (paruresis). The judgment was affirmed.
Sheehy claimed Fourth Amendment violation for illegal search and seizure. He claimed Eighth Amendment violation for deliberate indifference to serious medical needs for failure to diagnose paruresis, and for cruel and unusual punishment for subjection to a desegregation unit (DSU). He further claimed that his transfer affected his ability to litigate his case.
On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the summary judgment in its entirety. It was held that Sheehy failed to prove the testimony unreasonable or intent to harass. The court held that he failed to show that his prison transfer hindered his litigation and he did not allege a First Amendment claim for retaliation. It was held that his Eighth Amendment claim for conditions of confinement in the DSU showed no cruel or unusual punishment and that his deliberate indifference claim fell short because the medical staff was negligent at best. The court further held that no medical documentation backed his claim for paruresis. See: Sheehy v. Palmateer, 68 Fed. Appx. 77 (9th Cir. 2003).
Sheehy claimed Fourth Amendment violation for illegal search and seizure. He claimed Eighth Amendment violation for deliberate indifference to serious medical needs for failure to diagnose paruresis, and for cruel and unusual punishment for subjection to a desegregation unit (DSU). He further claimed that his transfer affected his ability to litigate his case.
On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the summary judgment in its entirety. It was held that Sheehy failed to prove the testimony unreasonable or intent to harass. The court held that he failed to show that his prison transfer hindered his litigation and he did not allege a First Amendment claim for retaliation. It was held that his Eighth Amendment claim for conditions of confinement in the DSU showed no cruel or unusual punishment and that his deliberate indifference claim fell short because the medical staff was negligent at best. The court further held that no medical documentation backed his claim for paruresis. See: Sheehy v. Palmateer, 68 Fed. Appx. 77 (9th Cir. 2003).
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Related legal case
Sheehy v. Palmateer
| Year | 2003 |
|---|---|
| Cite | 68 Fed. Appx. 77 (9th Cir. 2003) |
| Level | Court of Appeals |
| Injunction Status | N/A |