Supreme Court of Delaware

Brooks v. Lynch

October 13, 2016

Summary

The Court affirmed dismissal of Brooks’s complaint seeking declaratory and mandamus relief concerning ultraviolet treatment for vitiligo. It held that declaratory relief was unavailable because the prison grievance process had already addressed the dispute and the individual defendants lacked a cognizable interest in the grievance decision, while mandamus was unavailable because Brooks lacked a clear right to a nondiscretionary duty and sued improper respondents. The Court also held that the claims were substantively medical-malpractice claims requiring an affidavit of merit, and therefore did not reach the statute-of-limitations issue.