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Gates v. Huibregtse
Citation: 69 F. App'x 326Docket: No. 02-2887
Court: Court of Appeals for the Seventh Circuit; June 6, 2003; Federal Appellate Court
Sammy Gates, a Wisconsin prisoner, alleges violations of the Eighth Amendment and due process rights related to his punishment involving a ten-day diet of nutri-loaf, a blended prison food served without utensils. Gates experienced severe digestive issues, including vomiting and ultimately vomiting blood, after consuming the nutri-loaf. He sought assistance from a prison nurse, Belinda Schrubbe, who recommended adjustments but did not alleviate his symptoms. His requests to Warden McCaughtry and Deputy Warden Deppisch to be removed from the diet were denied, resulting in a weight loss of six pounds. Initially, a district court dismissed Gates's complaint without prejudice for failing to state a claim, which was deemed erroneous as dismissals under 28 U.S.C. § 1915A(b)(1) should be with prejudice. Gates voluntarily dropped his appeal after a request to proceed in forma pauperis was denied. He later filed a more detailed complaint in another district, seeking damages and a requirement for hearings before imposing nutri-loaf diets. The defendants responded with a motion to dismiss, citing failure to state a claim and qualified immunity. The district court agreed with the defendants, ruling that Gates did not demonstrate an Eighth Amendment violation and that due process was not violated by the lack of a hearing. Gates's claim that a nutri-loaf diet constitutes cruel and unusual punishment was deemed frivolous, as prison food must be nutritious but not necessarily appetizing. While Gates hinted at a more specific Eighth Amendment claim against Schrubbe for her inaction following his complaints, he needed to prove he faced a serious deprivation and that she was deliberately indifferent, which he did not sufficiently establish in his allegations. Deprivation of food for an inmate can be objectively serious, but in this case, Schrubbe was not found to be deliberately indifferent to Gates's complaints of nausea. Gates only communicated that he had experienced stomach issues on two occasions over four days, without indicating any severe symptoms like vomiting blood. Schrubbe's response, which included advice on hydration and portion size, was deemed reasonable and sufficient, thereby negating his Eighth Amendment claim. Additionally, Gates's argument that the Fourteenth Amendment required a hearing before his placement on a nutri-loaf diet was rejected. The court clarified that not every adverse change in prison conditions necessitates due process; only those that impose atypical and significant hardships compared to ordinary prison life warrant such protections. A temporary diet of a meatloaf-like substance does not rise to this level. Gates has also accumulated three "strikes" under 28 U.S.C. § 1915(g), limiting his ability to file future civil suits in forma pauperis, leading to the affirmation of the lower court's decision.