Woodroffe v. Nooth

Past deliberate indifference is insufficient to support habeas relief.

Woodroffe, an inmate at Snake River Correctional Institution (Snake River), appealed the trial court’s dismissal of a writ of Habeas Corpus. Woodroffe argued that he presented sufficient evidence to establish disputed issues of material fact as to whether Nooth, Snake River Superintendent, was deliberately indifferent to his medical needs including knee pain, a fractured coccyx, ADHD, and migraines. After an x-ray showing possible damage to the knee, Woodroffe requested a surgical consult which was denied, his medication for migraines was changed, and his ADHD medication was stopped. Regarding the surgical denial, the Court of Appeals found that Woodroffe did not provide evidence that the denial was based on the cost of treatment or any other impermissible cost-benefit analysis. Regarding Woodroffe’s changed migraine medication, he did not proffer evidence of improper motive or deliberate indifference that was continuing at the time the habeas petition is adjudicated. Additionally, Woodroffe did not inform doctors at Snake River that any changed or discontinued treatment was less effective. Accordingly, the trial court did not err in dismissing plaintiff’s habeas petition. Affirmed.