Frohmader, however, responded only with conclusory and self-serving excerpts from his deposition where he stated that he was so debilitated by
claustrophobia and
agoraphobia that medical intervention was constitutionally mandated. Frohmader presented no affidavits or depositions of experts, nor any other form of medical or psychological evidence, reflecting a diagnosis of
claustrophobia. As for his alleged
agoraphobia, Frohmader presented a letter to his attorney from a mental health professional, Michael Schmidt, Ph.D., which contained a single unelaborated reference to Frohmader's “history of
agoraphobia,” and added only that Frohmader “did improve” under treatment. However, Frohmader never indicated by way of allegation or deposition testimony, much less substantiated by medical evidence, how this condition, defined as a fear of wide-open public places particularly where crowds are found,
see Merck Manual of Diagnosis and Therapy at 1504 (15th ed. 1987); Dorland's Illustrated Medical Dictionary at 41 (26th ed. 1985), was implicated by his confinement, alone, in a jail cell.