UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF
PENNSYLVANIA
AARON CARTER,
Plaintiff,
v.
ALLEGHENY COUNTY, ALLEGHENY COUNTY JAIL MEDICAL DEPARTMENT,
PRIMECARE MEDICAL, INC., and WELLPATH HEALTHCARE,
Defendants.
Case No.: _________________
2:25-cv-01156-CBB
CIVIL COMPLAINT
(MEDICAL NEGLIGENCE, CONSTITUTIONAL VIOLATIONS, AND DEMAND FOR JURY
TRIAL)
I. INTRODUCTION
Plaintiff Aaron Carter brings this action to redress egregious violations of his constitutional
rights and medical negligence suffered while in the custody of Allegheny County Jail. Despite
his well-documented diagnosis of severe, life-threatening psoriasis, Plaintiff was deliberately
denied access to essential and prescribed biologic treatment while incarcerated, resulting in
catastrophic deterioration of his health. The named Defendants, through policies of indifference
and gross medical malpractice, inflicted permanent physical injury, extreme emotional trauma,
and placed Plaintiff at risk of amputation, systemic infection, and death.
This Complaint seeks justice for the inhumane treatment Plaintiff endured under color of law,
and to hold the responsible governmental and corporate entities accountable under both federal
and Pennsylvania law.
II. PARTIES
1 Aaron Carter is an adult individual and resident of Allegheny County, residing at 914
Berry Street, Pittsburgh, Pennsylvania 15204.
2 Allegheny County is a political subdivision of the Commonwealth of Pennsylvania,
responsible for operating and overseeing the Allegheny County Jail and its contractors.
3 Allegheny County Jail Medical Department is an agency of Allegheny County and is
responsible for the provision and supervision of all inmate medical care within the jail.
4 PrimeCare Medical, Inc. is a private, for-profit healthcare provider with headquarters at
3940 Locust Lane, Harrisburg, PA 17109, and contracted to provide medical services to
inmates in correctional facilities, including Allegheny County Jail.
5 Wellpath Healthcare is a nationwide corporate medical provider with headquarters at
1283 Murfreesboro Pike. Nashville, TN 37217, which at relevant times was responsible
for medical staffing and care at Allegheny County Jail.
III. JURISDICTION AND VENUE
6 This Court has jurisdiction over the subject matter of this action pursuant to 42 Pa.C.S. §
931 and § 8522, as the claims arise from actions of county officials, agents, and
contractors.
7 Venue is proper in Allegheny County pursuant to Pa.R.C.P. 1006(a), as the events giving
rise to this claim occurred in this jurisdiction.
IV. FACTUAL BACKGROUND
8 Plaintiff was incarcerated in Allegheny County Jail from September 4, 2024 to April 8,
2025, during which time he suffered from severe chronic plaque psoriasis, a serious
autoimmune disease that requires continuous, biologic immunosuppressive treatment.
9 Prior to incarceration, Plaintiff was under care of a licensed dermatologist and received
monthly Taltz (ixekizumab) injections—an FDA-approved, life-saving biologic
medication necessary to prevent widespread outbreaks, internal inflammation, and
permanent damage.
10 Upon intake and throughout his detention, Plaintiff made multiple verbal and written
notifications to jail medical personnel of his diagnosis, medication, and treatment plan.
11 Despite clear medical necessity and repeated urgent requests, Defendants willfully
refused to provide the prescribed treatment, citing the high cost of biologic medication
and inability to accept Plaintiff's insurance.
12 Instead, Plaintiff was improperly prescribed topical steroids and oral corticosteroids,
which are contraindicated for severe psoriasis and known to worsen the disease.
13 These substitute treatments caused rapid deterioration of Plaintiff's condition—resulting
in open lesions, cracked and bleeding skin, swelling, severe pain, and risk of systemic
infection and limb loss.
14 Plaintiff’s repeated requests for outside hospital referral, Aquaphor, or emergency
intervention were ignored or denied, despite visible, worsening symptoms and increasing
physical disability.
15 By early 2025, Plaintiff’s condition became so critical that he was emergently released
from custody on April 8, 2025, in lieu of providing life-sustaining medical care.
16 Plaintiff continues to suffer permanent injuries, including nerve damage, chronic
inflammation, severe pain, skin scarring, emotional distress, and significant impairment
to quality of life.
17 Attached as Exhibit A is a photographic depiction of Plaintiff’s condition, evidencing the
extent and severity of the untreated disease at the time of this filing.
V. CAUSES OF ACTION
COUNT I – MEDICAL NEGLIGENCE / MALPRACTICE
(Against PrimeCare Medical, Wellpath Healthcare, and Jail Medical Staff)
18 Plaintiff incorporates all prior paragraphs as if fully set forth herein.
19 Defendants owed Plaintiff a legal duty to provide competent and medically appropriate
care while in their custody and under their control.
20 Defendants breached this duty by failing to evaluate, treat, or refer Plaintiff for his known
condition, and by providing contraindicated medications.
21 These actions constitute gross medical negligence and fell far below the standard of care
required by Pennsylvania law and medical ethics.
22 Plaintiff suffered serious physical harm, permanent injury, and emotional trauma as a
direct and proximate result.
COUNT II – VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983
(Against Allegheny County, Jail Medical Department, and Medical Contractors)
23 Plaintiff incorporates all prior paragraphs as if fully set forth herein.
24 Defendants, acting under color of state law, exhibited deliberate indifference to Plaintiff’s
serious medical needs in violation of the Eighth and Fourteenth Amendments to the U.S.
Constitution.
25 Plaintiff was a pretrial detainee and entitled to basic human care and medical treatment
under clearly established constitutional law. See Estelle v. Gamble, 429 U.S. 97 (1976);
Monmouth County v. Lanzaro, 834 F.2d 326 (3d Cir. 1987).
26 Defendants’ refusal to provide life-sustaining care, in favor of cost-saving measures,
constitutes conscious disregard for Plaintiff’s health and constitutional rights.
27 Under Monell v. Dept. of Social Services, 436 U.S. 658 (1978), municipalities and
contractors are liable where customs, practices, or policies result in constitutional
violations—such as here.
COUNT III – VIOLATION OF PENNSYLVANIA CONSTITUTION, Article I, § 1
(Against All Defendants)
28 Plaintiff incorporates all preceding paragraphs.
29 The Pennsylvania Constitution guarantees the right to life, liberty, and bodily integrity.
Defendants' failure to provide critical medical treatment constitutes a violation of these
protections.
30 Plaintiff was forced to endure avoidable pain, trauma, and disfigurement at the hands of
government actors and their agents in deliberate violation of these rights.
VI. DAMAGES
As a direct and proximate result of Defendants' conduct, Plaintiff has suffered:
• Exacerbation of a life-threatening autoimmune disorder;
• Physical disfigurement and pain;
• Permanent nerve and skin damage;
• Risk of sepsis, amputation, and death;
• Severe emotional trauma, anxiety, and psychological distress;
• Loss of dignity and constitutional harm;
• Ongoing and future medical costs.
VII. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in his favor and
award:
1 Compensatory damages in excess of $50,000;
2 Punitive damages for reckless and willful conduct;
3 Injunctive relief requiring Allegheny County to reform its jail medical policies;
4 Costs of litigation, including expert and filing fees;
5 Any other relief the Court deems appropriate in law or equity.
VIII. DEMAND FOR JURY TRIAL
Plaintiff hereby demands a trial by jury on all issues so triable.
Respectfully submitted,
____________________________
Aaron Carter
Plaintiff, Pro Se
914 Berry Street
Pittsburgh, PA 15204
Date: _______________________